ML20065G980
| ML20065G980 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 04/05/1994 |
| From: | NEBRASKA PUBLIC POWER DISTRICT |
| To: | |
| Shared Package | |
| ML20065G978 | List: |
| References | |
| NUDOCS 9404130381 | |
| Download: ML20065G980 (110) | |
Text
,
i' NEBRASKA PUBLIC POWER DISTRICT COOPER NUCLEAR STATION OUALITY ASSURANCE PROGRAM FOR OPERATION POLICY DOCUMENT TABLE OF CONTENTS Corporate Policy Statement.............................. v 1.0 PROGRAM DEFINITION.............................
1-1 1.1 Purpose...................................
1-2 1.2 Poli cy....................................
1 -2 1.3 Objectives
..................................'l-5 1.4 Scope....................................
1-7 1.5 Definition of Terms............................
1-8 2.0
SUMMARY
DESCRIPTION..........................
2-1 2.1 Organization
...............................2-1 2.2 Quality Assurance Program.......................
2-2 2.3 Design Control 2-6 2.4 Procurement Document Control 2-13 2.5 Instructions, Procedures & Drawings 2-15 2.6 Document Control 2-17 9404130381 940405 i
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TABLE OF CONTENTS (Cont'd) 2.7 Control of Purchased Material, Equipment, and Services...............................
2-19 2.8 Identification and Control of Parts, Materials, and Components 2-21 2.9 Control of Special Processes 2-22 2.10 Inspection
................................2-22 2.11 Test Control...............................
2-25 2.12 Control of Measuring and Test Equipment 2-26 2.13 Handling, Storage, and Shipping
...................'2-27 2.14 Inspection, Testing, and Operating Status 2-29 2.15 Nonconfn 'ng Materials, Parts, or Components
......... 2-30 2.16 Corrective Action............................
2-33 2.17 _ Quality Assurance Records 2-34.-
2.18 Au d i t s...................................
2-35 2.19 Additional ANSI Standards 2-37 3.0 ORGANIZATION AND RESPONSIBILITIES 3-1 P
3.1 General...................................
3-1 3.2 Nuclear Power Group Management..................
3-2 3.2.1 Vice President - Production..................
3-2 3.2.2 Nuc! car Power Orcup Mar.cger yic(PiesidsiiEN6bisit. 3-2
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TABLE 'OF CONTENTS (Cont'd) 3.2.3 Division Manager, Quality Assurance............. 3-3 3.2.4 Quality Assurance pjiij6Ei@i Manager -GNS 3-5 3.2.5 Quality Assurance Ks55@ii@ Manager -C-GO 3-7 3.2.6 Quality Assurance Supervisors 3-9 1
3.2.7 Quality Assurance Staff..................... 3-9' 3.2.8 Division Manager Nuclear Engineering and Construction 3-11 3.2.9 N5_61siE_EB,sl[MAHsis..................... 3-12~
b 3.2.9{0 Plant Manager 3-12 3.2.-101] Site M=;;ct S_e, nioi..Ns.,. -,_D.,,.,,,M.
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-- c_ _m._mo..n.._. an...a., ge_ro ss_esst iv 3.2.44)2. Senior Manager - Site' Support..............
3-13 3.2.4213' Division Manager - Nuclear Support........... 3-13, a
2 4l 3.2.4313 g615ihlis'W5Fril{Offi5s (CGO) Department Managers 14 s
i 3.2.4315.C66psfN._U61EEE5iiti5.n (CNS) Department Manager 3-14 1
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3.3 Cooper Nuclear Station Personnel................... 3-14 3.4 CGO Personnel
............................. 3-15 3.5
' Safety Review and Audit Board (SRAB) 3...............
3.6 Station Operations Review Committee (SORC) 3-16.
3.7 Outside Suppliers, Contractors, Subcontractors, 7-4 1
4 e
and Consultants '.............................
3-16
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TABLE OF CONTENTS (Cont'd)
- 4.0 QUALITY ASSURANCE DOCUMENTS 4-1 4.1 NPPD Internal Documents 4-1 4.1.1 Quality Control Inspection 4-2 4.1.2 Nuclear Quality Procedures (NQP)..............
4-4 4.1.3 Quality Assuranee4nstruetions4QAI) Quality Assurance Plans (QAP) 4-5 4.1.1 Quality Assurance Plans (QAP) 44 5.0 METHOD OF IMPLEMENTATION.....................
5-1 6.0 RECORDS RETENTION AND DISPOSITION 6-1 l
7.0 R EFEREN C ES...................................
7-1 8.0 FIGURES 8-1 i
8.1 Quality Assu.ance Organizational Chart (Figure 1).........
8-1 9.0 TABLES 9-1 9.1 Systems and Components Within Scope of the CNS QA Program (Table 1) 9-1 aree F6ii' Level QA Program (Table 2) 9 -5 9.2 r
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CORPORATE POLICY STATEMENT This document establishes and describes the policies and practices of the Quality Assurance Program applicable to the operation of the Cooper Nuclear Station and the support activities of all NPPD Nuclear Divisions. The District's policy with respect to nuclear safety and quality assurance is detailed in Section 1.2 of this document.
Each Nuclear Division is responsible for the development of policies and procedures which implement this Quality Assurance Program. Other divisions and departments at NPPD may also have responsibilities under this program and shall comply as described in appropriate implementing procedures.
The Safety Review and Audit Board, Station Operations Review Committee, and the Quality Assurance Division shall monitor the District'.s nuclear program and provide l
management with evaluations and assessments regarding the effectiveness of the implementation j
of the program. V' hen evaluations and assessments identify a concern, management shall take expeditious action to correct any undesirable condition (s) including, where appropriate, action to preclude repetition of such condition (s).
District personnel shall have the organizational freedom to identify concerns and propose corrective and preventive action necessary to enharce the District's nuclear program.
The assurance of safe and reliable operatior of Cooper Nuclear Station is everyone's duty. Ouality shall be everyone's responsibility.
APPROVED:
President
-Nuclear Power Group Manager YI@YNidN[MNM Vice President - Production Division Manager - Quality Assurance v
Revision 10
1l COOPER NUCLEAR STATION OUALITY ASSURANCE PROGRAM FOR OPERATION POLICY DOCUMENT 1
1.0 PROGRAM DEFINITION In accordance with the conditions of the Nuclear Regulatory Commission construction permit and operating license for the Cooper Nuclear Station, the management of Nebraska Public Power District recognizes its responsibility for assuring that the Cooper Nuclear Station is designed, constructed, and operated in such a manner as to provide for the safety of the public. The importance of Quality Assurance in contributing to this safety as well as contributing to station reliability is also recognized.
The initial phases of the overall Quality Assurance Program, implemented during design and construction, provided an independent check for the work performed on components, structures, and systems of the station to assure that the design, analysis, materials of -
construction, manufacture, installation, erection, and construction met quality standards required to assure reliable and safe operation. The CNS Quality Assurance Program for Operation, as described herein, is implemented to provide an independent quality check -
on all phases of station operation, maintenance, and modification.
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1.1 Puroose i
o The purpose of this policy document is to provide a description of the Quality Assurance j
Program to be followed during the operational phase of Cooper Nuclear Station and to identify applicability of the policies and procedures described herein. This CNS Quality Assurance Program for Operation was developed by Nebraska Public Power District in response to the requirements of 10CFR50, Appendix B. It provides a general description of the Quality Assurance Program for Operation and requires that detailed instructions, procedures, and drawings, as appropriate, be set forth in writing and carried out by each of the responsible organizations or individuals within the District.
1.2 Pohcv It is the policy of Nebraska Public Power District (NPPD) to use its best efforts to assure that the Cooper Nuclear Station is designed, constructed, maintained, and operated in a manner that will provide the highest practical degree of safety and reliability. Structures, components, and systems are designed, fabricated, erected, maintained, and modified to quality standards appropriate to their importance to the safety function. The Quality.
Assurance Documents will identify those structures, systems, and major components to be covered by the Quality Assurance Program in order to provide continuing compliance with these standards throughout the operating life of the station. Additionally, it is the policy of NPPD that activities affecting quality shall be documented by approved instructions, procedures, or drawings and such activities shall be implemented as 1-2 Revision 10
i documented. Such documentation shall contain adequate qualitative and/or quantitative i
acceptance criteria to provide a measure of accomplishment.
It is the policy of Nebraska Public Power District (NPPD) to staff the Nuclear Power Group (NPG) with properly-trained personnel in all responsible positions and job assignments. Sufficient numbers oflicensed and r:nior licensed operating personnel will be available to assure proper operation of the station under all reasonably foreseeable circumstances including personnel turnover, vacations, and disability.
All District personnel, as well as non-District personnel who work independently under NPPD's QA Program, responsible for operating, maintaining, or designing safety-related systems and equipment shall receive formal instruction in Quality Assurance, including:
basic principles of quality assurance,10CFR50 Appendix B, the contents of this policy document, and Quality Assurance Documents, as applicable.
Trained technical, engineering, and Quality Assurance Pjsersonnel shall be assigned surveillance and audit tasks to ensure compliance with the requirements of the documents which control station operation, such as the NRC license, Updated Safety Analysis Report, Technical Specifications, Operating Manual, QA Program for Operation, and other such controlling documents.
During the time personnel are performing QA functions, they shall be responsible to the QA Division to maintain the organizational independence required by the QA Program.
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It is the policy of Nebraska Public Power District to maintain quality standards for Cooper Nuclear Station which will ensure the high degree of reliability and safety needed to meet the overall objectives of supplying safe and dependable electric service to its customers.
j The CNS QA Program for Plant Operations utilizes the guidance provided by NRC publications WASH-1283 (5-24-74), WASH-1284 (10-26-73), and WASH-1309 (5-10-74)
(" rainbow" series) except where specific exaptions and clarifications are noted within this document. Where specific requirements included in the standards are in conflict with original design requirements set forth in the USAR and other appropriate design l
documents, the original design requirements shall govern. Later revisions [@ii@j j
pp@ptifyn@ilyRTQypNQ may be specifically invoked by the design requirements where deemed appropriate, consistent with the overall commitment to maintain the plant in an " equal to or better than original" condition.
In summary, NPPD is committed to the continuous development of a Quality Assurance Program which will meet the requirements of 10CFR50, Appendix B, Quality Assurance Criteria for Nuclear Power Plants, and other applicable regulations as may be promulgated by the Nuclear Regulatory Commission. This commitment applies to all NPPD organizations to assme that a high standard of quality will be maintained during nuclear plan: operation. Section 2 of this document presents a summary discussion of.
the QA Program as applicable to the 18 criteria of 10CFR50, Appendix B.
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l 1.3 Objectives In accordance with the policy statements above, the overall objective of the CNS Quality Assurance Program for Operation, as defined in Quality Assurance Instructions (QAh),
Quality Assurance Plans (QAPs) and Nuclear Quality Procedures (NQPs), is to set forth the Quality Assurance organizational structure and personnel responsibilities and to set forth general requirements for the preparation of written procedures and controls necessary for quality surveillance and auditing to verify the following:
a)
Regulatory criteria, codes and standards, and design bases for safety-related systems (as defined in the CNS QA Program) are incorporated into the test, operating, modifications, and maintenance procedures and instructions to meet all requirements for nuclear safety and station reliability; b)
Results of all preoperational and operational tests of safety-related systems and components conform to the requirements of the drawings, specifications, procedures, and instructions, and that appropriate reports are prepared to document that all results of tests meet prescribed acceptance criteria; c)
Nuclear Fuelis purchased, designed, manufactured, inspected, packaged, shipped, received, installed, and operated in the reactor in accordance with approved procedures, instructions, regulatory requirements, and license stipulations; 1-5 Revision 10
a l
d)
The Station is operated, maintained, tested, refueled, repaired, and modified, in accordance with approved procedures, instructions, regulatory requirements, and license stipulations, consistent with quality standards equal to or better than those in effect during design and construction; e)
A system is established and maintained to control, safeguard, and permit ready retrieval of quality-related documentation generated for materials and components during the design, fabrication, modification, maintenance, and operation of CNS; f)
Appropriate and complete reports, records, and logs are established and maintained so as to provide a continuing record of quality-related activities associated with station safety and reliability throughout the life of the station; g)
The NPG personnel are subjected to periodic training, retraining, requalification, and examination such as to maintain and improve their job skills which are essential to safe and reliable operation of the station; h)
Station security and nuclear fuel accountability and safeguards are maintained in accordance with approved procedures and instructions; i)
CdrfEclifi[sEli6fi Ncnconformance reports pl66[Widi^1Esifiss51jiti6 tis are to be -
properly resc!ved and filed in the quality-related record files; j)
Inspection reports issued by the NRC are properly resolved and documented; l-6 Revision 10 i
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k)
Spent fuel shipment activities are to-be accomplished in accordance with regulatory requirements (10CFR Part 71).
1.4 Sc.gpq The QA Program for Operation applies to those nuclear station structures, systems, and components that are designed to prevent or mitigate the consequences of postulated accidents which could cause undue risk to the health and safety of the public, and to other selected systems and programs as oefined in implementing QA Plans. The requirements of this program apply to all activities which affect the safety-related functions of those structures, systems, and components, including designing, purchasing, fabricating, handling, shipping, storing, cleaning, erecting, installing, inspecting, testing,.
operating, maintaining, repairing, refueling, in-service inspection, and modifying.
This program specifically applies to, but is not necessarily limited to the nuclear fuel, the -
reactor coolant system and its auxiliaries and controls, the reactor protection and engineered safety systems, the reactor containment system, portions of the radioactive waste disposal system, and other systems and components required for safe, efficient, and b
reliable operation of the plant. A tabulation of those structures, systems, and components which are covered by the QA Program is given in Table 1.
The Quality Assurance activities governing those structures, systems, and major components shall be performed as described in the Quality Assurance Plans (QAPs) (see Section 4.1.3).
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l The Quality Assurance Criteria in 10CFR50, Appendix B, are oriented primarily toward engineering, manufacturing, and construction activities. _ Therefore, it is necessary to
.I define, by specific Quality Assuunce Documents, the manner in which the NRC Quality Assurance Criteria are to be applied to the station operating activities. Such Quality I
Assurance Documents shall be prepared in accordance with the requirements specified lI in Sections 2.0 and 4.0 of this policy document, i
1 l
The specifications, principles, and procedures which controlled the original procurement, fabrication, and construction have been carried over into the QA aspects of station operation to the greatest extent practicable, it is the intent of NPPD management to maintain, as a minimum, the quality level achieved in the original design and construction.
l 1.5 Definition of Term; Key words and phrases used to characterize this QA Program are defined herein to establish a basis for uniform and consistent interpretation of the Quality Assurance requirements. Definitions of these terms are based upon documents and standards issued by the American National Standards Institute (ANSI), NRC Safety and Regulatory Guides, professional societies involved in standards work (ANS, ASME, IEEE, et al.),
and on the basis of contemporary usage in the nuclear power industry; or shall be defined specifically to convey the intent of this particular program. Specific to the related ANSI Standard for this subject, the following commitment applies:
l l-8 Revision 10
h ANSI N45.2.10-1973 " Quality Assurance Terms and Definitions," and the associated Regulatory Guide 1.74, are applicable to the CNS Operational' QA Program, with the following clarification:
i There may be instances where existing procedures contain definitions that may not be in strict accordance with those provided by this standard. As existing 1
procedures are revised, however, such definitions shall be evaluated to assure that all definitions meet those provided by this standard.
1 I
To faciliSte review and understanding of this policy document, the following basic terms are defined below along with appropriate QA Program requirements.
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For piping and valves, CLASS is determined by the applicable ASME Code. For seismic considerations, CLASS is determined by the USAR.
(See also Essential, Non-Essential, and Quality Commercial Grade.)
Codes and Standards Documents issued by qualified organizations which contain standardized requirements for particular equipment or applications (e.g., ASTM Material Standards, ASME Pressure Vessel Code, etc.).
(Refer also to ANSI N45.2.10 for defm' ition of " Standard".)
Controlling Documents All those drawings, specifications, procedures, instructions,. manuals, data books,.
c.
Updated Safety Analysis Reports (USAR), Technical Specifications, and the like, which 1-10 Revision 10 L
have been, appe-~i and issued by the appropriate authorities, and which prescribe the conditions and limitations under which work is to be performed.
(Refer also to ANSI N45.2.10 for definition of " Documentation".)
Design Change A design change (generic application) is considered to be any change to a component,-
equipment, or structure that changes the design criteria, configuration, or margin of safety for a system or component which could impact nuclear safety, equipment and system integrity, or personnel safety. For the purposes of definition, " design change" includes Design Changes, Equipment Specification Chenges, etc.
Designated Representatives R
An individual or organization thitlis authorized by the purchaser to perform R5@ifid function Eslid6nyfied;lidiilis in procurement il6diliisiil proeess.
Emergency Procedures (Operating, Maintenance, or Repair)
Those activities which must be performed without delay in order to:
1-11 Revision 10
l a).
Avoid further degradation of off-normal conditions which, in themselves, do not constitute an accident, but which could lead to an accident if not corrected o
promptly; j
b)
Reduce the consequences of an accident or hazardous condition which has already l
occurred; c)
Implement an emergency plan; d)
Prepare for an anticipated act of nature.
Essential For purposes of applying and implementing this Quality Assurance Program, the term
" Essential" shall apply to the following:
a)
All systems, structures, equipment, and components which are identified in the USAR as having been designed and built to Seismic Class I requirements; b)
All systems, structures, equipment, components, instruments, and controls which are identified in the USAR as being required to shut down the plant and maintain it in a safe shutdown condition; 1-12 Revision 10 I
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All other systems, structures, equipment, components, instruments, and ' controls w c are p aced in the " Essential" category by NPPD.-
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Functional Organization Chart 4
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A pictorial description of the organization as it actually works showing actual lines of-direction, supervision, responsibility, authority, and communication. Such functional lines may or may not coincide with regular administrative channels.
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j Inspection The determination that physical characteristics meet predetermined requirements by visual checks or by other techniques such as X-ray, ultrasonic or dye penetrant examination, 1
etc. (See also Quality Control).
(Refer also to ANSI N45.2.10 for definition of " Inspection".)
'1 Licensed Station I
h A nuclear station which is designed and constructed so'as to meet requirements of I
applicable regulatory criteria and is thereby eligible to receive a construction permit and operating license from the U.S. Nuclear Regulatory Commission.
Lower Tier Procurement Procurement by a supplier from a subsupplier of items or services.
Maintenance Procedures Written instructions which define a preplanned maintenance program and prescribe the methods, materials ~, and processes to be used to assure continuing quality and continuing operation of equipment within required performance characteristics.
1-14 Revision 10 -
Maior Maintenance. Repair. or Modification I
Those maintenance, rgair, or modification activities performed on nuclear safety-related structures, systems, or components which involve:
a)
Special craft or procedure qualifications to meet Code, Standard, or Regulatory requirements; b)
Alterations which affect overall structural integrity, essential performance characteristics, or margins of safety in design for nuclear safety-related structures,.
systems, or components; c)
Any permanent change to the facility that requires a Technical Specification change or creation of an unreviewed safety question.
Minor Maintenance. Repair. or Modification Those maintenance or repair activities which are within a journeyman craftsman's capability, and which:
a)
Are prescribed in the equipment manufacturer's instruction books as necessary or desirable for most effective operation; l-15 Revision 10 -
i b)l
. Are prescribed as part of a preplanned and approved routine or preventative maintenance program; c)
Any permanent change to the facility judged significant enough to warrant E
documentation that does not require a change in Technical Specification or present an unreviewed safety question.
c-Monilar Periodically observe on a formal or informal basis whether work is being performed according to the requirements of the controlling documents (see also Surveillance).
l Nonessential Any structures, equipment, and components which may be important to reactor operation, _
but are not required for preventing an accident which would endanger the public health and safety, and are not required for the mitigation of the consequences of these accidents.
A Nonessential designated item shall not degrade the integrity of any item designated Essential.
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~ Nuclear Ouality Procedures Procedures controlled by the Quali'.y Assurance Division that contain requirements which affect the activities of other divisions of NPPD.
Off-Normal Condition A condition which results when an operating variable departs from its normal range. To restore normal operating conditions following such a perturbation, action is taken under off-normal procedures so as to correct the condition which, if not corrected, could -
degenerate into a condition requiring action under an emergency procedure.
Operating Procedures Written instructions which define the normal method, means, and limits of operation, in all modes, of a nuclear power station, a system or systems within the station, or station processes.
Purchaser The organization responsible for issuance or administration or both of procurement.
documents.
(Refer also to ANSI N45.2.10 for definition of " Purchaser".)
1-17 Revision 10
Ouality Assurance All those planned and systematic actions performed for the purpose of establishing a high level of confidence that:
a)
Work performed on the project conforms with the requirements of the applicable'-
codes, standards, license stipulations, safety analyses, design drawings,.
speciGcations, procedures, and instructions; b)
A structure, system, or component will perform satisfactorily in service; and c)
Appropriate records, documentation and/or drawings are maintained to show compliance with a) and b) above.
Ouality Assurance Documents Those documents inclusive of the QA Policy Document, Nuclear Quality Procedures, QA Plans, QA-Instreetions Procedures (and associated data sheets), logs, etc., which r
have been approved for use, and whose intended function is to provide direction, verincation, or documentation for activities affecting quality.
1-18 Revision 10
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Ouality Assur=ce instruction:;
Quality Assurance Instructions define $c respon:;ibiliIc:; for impicmen'ation of Sc QA "rcgmm in acecrd=ce viii policies and p=ctice:; herein defined a:; icy apply 'c q
1 the QA Division. In addition, they provide guid=ce for surveill=ce =d =dit activitics
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l Ouality Assurance Plans i
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i Quality Assurance Plans are those documents specifically designed to provide detailed j
quality requirements for a given functional area. The plans are generated by applying -
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the 18 criteria of 10CFR50, Appendix B, to each functional area and then deriving the specific quality requirements for that area.
Ouality Assurance Records Those records (see Reference 7.9) which have been completed and furnish documentary evidence of the quality of items and/or activities affecting quality.
A document becomes a Quality Assurance Record when the activity related to the document becomes part of the operating condition of the plant.
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1-19 Revision 10
' Ouality Commercial Grade Classification of a Commercial Grade Item (CGI) intended for safety-related use, procured from a Q.A. approved source and dedicated in accordance with Procedure 1.13; which meets the 10CFR21 definition of CGI.
Commercial Grade Item (CGI) - An item that meets all of the following criteria:
a)
Not subject to design or specification requirements unique to nuclec facilities or activities; b)
Used in applications other than nuclear facilities or activities; and c)
Is ordered from the manufacturer's published product description, e.g. catalogue, as an off-the-shelfitem.
Ouality Control Those activities which deal directly with the measurement, observation, or verification of physical characteristics of materials, components, or systems which provide a basis-for controlling quality to within predetermined limits, or requirements, including-_
adequate quantitative and/or qualitative acceptance criteria by which an activity can he measured.
1-20 Revision 10
Ouality Requirements Those factors which define limits which must be met so that the product will perform its intended function' reliably throughout its design life. They include, but are not limited to, conditions important to proper material selection, manufacture, construction, and inspection; substantiation that matei or parts conform to all specification requirements, testing to demonstrate adequacy of performance; protection of finished parts to prevent deterioration; and conditions for operation, maintenance, and repair which enable continuing operation within prescribed margins of safety and within prescribed performance limits.
Rieht of Access The right of the purchaser or designated representative to enter the premises of a supplier for the purpose of inspection, surveillance, or quality assurance audits.
Reculatory Criteria That body of NRC publications which define the conditions which must be met to obtain and hold an NRC Construction Permit, Operating License, and Licenses for individual 4
operators.
k 1-21 Revision 10
~
~
w.
Review A deliberately critical examination. The term ine'.udes the routine monitoring o'f station operation performed by the Site M c.r.;;cr gj@@@@@gand his staff.as a
. normal. management function, and. the formal independent' cvaluations of certain contemplated actions and after-the-fact investigation of anomalies conducted by a ' duly.
constituted review and audit group.
Safeguard (of Nuclear Material)
Measure taken to prevent diversion of nuclear materials into unauthorized or illegal uses (see also Accountability).
Safety-Related (See " Essential")
Services The performance by' a supplier of activities such as design,- fabrication, inspection,.
nondestructive examination, repairs,' installation, or training, i
~ 1-22
- Revision 10'
Significant Conditions Adverse To Ouality Any conditions that could affect safety-related structures, systems, or components ability a
g to function within design requirements or adversely alter performance characteristics.
Station Permanent Record File The file which is established for the purpose of accumulating and storing all documents and records pertaining to quality-related activities throughout the life of the nuclear plant.
Suoplier Evaluation Those activities which determine the effectiveness of implementation of the supplier's Quality Assurance Program. A va-icty of methods may be used to perform a supplier evaluation and are described in the NQPs.
l Surveillance Surveillance is the QA Audit function consisting of formal and informal observations to determine that work is being performed in accordance with the requirements of the controlling documents and drawings (see also Audit and Monitor). Surveillance activities.
1-23 Revision 10
9 shall be performed in accordance with requirements specified in NQPsy Edd, QAPs and r
QMs.
Surveillance Testin_g Periodic testing of structures, components, and systems related to nuclear safety, for the purpose of verifying that such safety-related structures, components, and systems continue to function or are in a state of readiness to perform their safety functions.
1 H
l Testing The determination or verification of the capability of an item 'to meet specified requirements by subjecting the item to a set of physical, chemical, environmental, or operating conditions.
(Refer also to ANSI N45.2.10 for definition of " Testing.).
Traceability The capability to identify a particular component or material and to 'hcover its entire history, back through the written records of its material formulatmo (heat number),
1-24 Revision 10
r
(~;c manufacture, inspection, installation, test, operation, maintenance, repair, and.
replacement.
Witness Formal observation by a knowledgeable person of a particular, prescheduled event during manufacturing, inspection, installation, testing, operation, maintenance, or repair. The -
purpose of witnessing is to provide direct observation and evaluation of an event, independent of the group performing the particular operation.
1 l
i l
1
(
l-25 Revision 10 C.
2.0
SUMMARY
DESCRIPTION This section defines the NPPD commitment for compliance to 10CFR50, Appendix B, as applied to safety-related structures, systems, and components associated vith Cooper Nuclear Station.
In addition to describing commitments to 10CFR50, Appendix B, this Section also identifies NPPD's commitment to selected ANSI Standards and their associated Regulatory Guides.
2.1 Drgani7ation The President and Chief Executive Officer (C.E.O.) (Figure-13 represents the highest level of management responsible for establishment of Quality Assurance policies, goals, and objectives. The responsibility and authority for nuclear facility and General Office support activities (including QA) has been delegated to the Nuelear Power-Group Manager Vic6 Prisident3Nuclesi through the Vice-President - Power Production. This authority includes the right to direct, enforce, and perform any action required to ensure all activities conducted at Cooper Nuclear Station are in compliance with 10CFR50, Appendix B..In addition, the personnel assigned to the Quality Assurance Division 'shall have complete independence to perform audits, surveillances, in'spections, verifications].
Essessinen6[cyaluati6ni and shall be independent of those groups performing, designing, purchasing, fabricating, shipping, storing, cleaning, erecting, installing, inspecting, testing, operating, maintaining, repairing, refueling, in-service inspecting, and modifying.
2-1 Revision 10
Figure 4-of-this-doeument-outlines-the QA Divisica functional-organizatioth Quality Assurance Personnel shall have sufficient authority and organizational freedom to:
(1)
Identify quality problems; (2)
Initiate, recommend, or provide solutions for conditions adverse to quality; and, (3)
Verify implementation of solutions.
2.2 Ouality Assurance Progam j
The program shall be implemented in accordance with written, approved Nuclear Quality Procedures siid Quality Assurance Plans atuWastructions developed by the Quality
)j Assurance Division. The District's QA Program will comply with the Quality Assurance j
Guidelines contained in the Orange Book - WASH,- 1284-10-26-73. Design Control, I
Procurement Control, Quality Control, and Quality Assurance activities associated with plant modifications will similarly conform to the guidances provided 'within the Gray U
Book - WASH,1283-Rev.-l and the Green Book - WASH, 1309-5-10-74. Procedures will be prepared for each important activity of station operation which will clearly define i
the work to be performed on a step-by-step basis and will' identify, where appropriate, the results to be achieved. Mandatory QC Inspections or-Tests will be performed on an independent basis to verify that spscifi(M6fk36fifille[U6%iR66riectif"E6ispihtss]
n procedures +re+eing4ollowed (correct results obtained) and will be incorporated into the -
2-2 Revision 10 a
work procedures directly or by attachment. QA Audit activities will verify that the Quality Control Program is implemented.
Specific to the related ANSI Standards for this criterion, the following commitments apply:
1.
ANSI N18.1-1971 " Selection and Training of Nuclear Power Plant Personnel,"
shall provide direction for selecting and training of personnel for the Nuclear Power Group.
2.
ANSI N18.7-1972 "American National Standard for Administrative Controls for Nuclear Power Plants," and the associated Regulatory Guide 1.33, apply to the CNS Operational QA Program with the same exceptions as those taken in other sections of this Policy Document to ANSI N45.2-[1243.
f-.
l I
3.
ANSI N45.2-1977 " Quality Assurance Program Requirements for Nuclear Facilities," and associated Regulatory Guides 1.28 and 1.33, shall apply to the CNS Operational QA Program, with the following exceptions:
(a)
Where Section 11 " Inspection" identifies the reporting relationship between the inspector and the "immediate supervisors who are responsible j
f for the work being inspected," the CNS QC Program only requires that i
i 2-3 Revision 10
the individual performing the verification function shall not perform or directly supervise the work being inspected.
Table 1 identifies the structures, systems, and major components associated with Cooper j
Nuclear Station covered by this program. Table 1 is not intended to be all inclusive.
The Nuclear Operations, Nuclear Support and Nuclear Engineering and Construction Divisions, with the assistance of the QA Division, will identify essential structures, systems, and components to be included within the scope of the QA Program. The-Quality Assurance Program is designed to provide control over all activities affecting quality of essential items to a degre,: consistent with their safety-related importance.
These activities will be governed by approved plans and instructions and these documents H
shall be followed under controlled conditions.
The Quality Assurance' Plans and l
I Instreetions and the Nuclear Quality Procedures will be reviewed periodically to assure that the requirements of the program are being met and new requirements are being incorporated.
In addition to essential structures, systems, and components, applicable portions of this i
program shall be applied to selected nonessential structures, systems, and components important to station reliability and performance. Specific application will be identified in dedicated Quality Assurance Plans.
Special process controls, test equipment, tools, skills (training, if required)~shall be used during the conduct of inspection, verification and checking activities to assure a high standard of quality and reliability has been obtained on safety-related items covered by '
j I
f 2-4 Revision 10
the Quality Assurance Program. Test equipment and special tools will be calibrated against a specified secondary standard.
Experienced individuals (which may include personnel from other divisions of the Nuclear Power Group (NPG), and/or outside qualified individuals) may be requested to assist in performing audits and inspections of certain CNS quality-related activities at the -
direction of the Division Manager of Quality Assurance. During these assignments, these individuals will have sufficient organizational freedom to identify and recommend corrections for quality deficiencies noted.
The Nuclear Training Department, in addition to QA Staff personnel, provides QA indoctrination for NPG cmployees as described in nuclear training program descriptions. In addition, QA Staff members will attend a minimum of one training seminar / course per year sponsored by a qualified agency and/or school. Some courses provided by the District's Nuclear Training Department shall be considered applicable to meeting this requirement. Such determination shail be made by the Division Manager of Quality Assurance. For the purposes of meeting this requirement, activities such as attendance at national conventions, participation in owners group committee's activities, and other such related items may be considered equivalent to a seminar. Such instances 1
shall be specifially approved by the Division Manager of Quality Assurance. Ongoing.
QA trainir.g for personnel willi nuclear plant responsibilities will be provided. Training activities will be audited periodically by the QA Staff to verify its. scope and effectiveness, 2-5 Revision.
I 2.3 Design Contro]
Implementing procedures outline the method for identifying, controlling, and
. implementing design changes within the Cooper Nuclear Station. The procedures provide the mechanism for correctly translating the design changes and regulatory requirements into specifications, drawings, procedures, and instructions. They also establish the method of reviews, interface requirements (with original design organization, if required), approvals, and the organizations delegated the authority to implement the design change.
Design control measures shall include the review for suitability of application of items that are essential to the safety-related function of the system involved. A necessary part of this review concerns the safety classification of items to be procured. In those instances where the normal methods of Section 2.7 cannot be applied and it is necessary to purchase " commercial-grade" off-the-shelf items for use in essential applications, verification will be performed to ensure that the part utilized is functionally acceptable for the essential application. This verification may include dedication upon receipt, analysis, or other definitive method.
All Ijesign changes initiated for Cooper Nuclear Station will be for=ded to the QA-Division for.iihd6ililj review &l and independentlj evaluatiilien darI5GA Ejaliiiii6hs)f^sschis5sgj{A,Iidiis[6rijisfeilladdBs. These reviews shall verify the compatibility of the design change with applicable codes, standards, and regulatory requirements. Items to consider include reactor physics, stress, thermal hydraulic and 2-6 Revision 10
.~
f accident analyses, compatibility of materials, accessibility for in-service inspection, maintenance, repairs, and delineation of acceptance criteria for inspection and tests.
Final accept:mcc of the design change will require an independent verification or check of the design adequacy such as by the performance of design reviews, by the use of alternate or simplified calculational methods, or by the performance of a suitable testing program.
Specine to the related ANSI Standards for this criterion, the following commitments apply:
1.
ANSI N45.2.11-1974 " Quality Assurance Requirements for the Design of Nuclear Power Plants," and the associated Regulatory Guide 1.64, shall be applied to 4
design activities involving safety-related modification work and the revision or development of plant design documents occurring during the operational phase of CNS..However, where codes, standards, or design requirements are referenced, or are incorporated into the standard by reference, which are in conflict with.
'l j
i original design commitments as set forth in the Updated Safety Analysis 1
'I Repcrt (USAR), the USAR commitments shall govern.
Later. revisions of applicable codes and standards may be'specifically invoked by the design requirements where deemed appropriate, consistent with the overall commitment 1
a to maintain the plant in an "egt'al to or better than" original condition.
j i
2-7 Revision 10 '
2.
ANSI N45.2.4-1972 " Installation, Inspection, and Testing Requirements for Instrurnentation and Electric Equipment During the Construction of Nuclear Power Generating Stations," and its associated Regulatory Guide 1.30, shall be applicable to the CNS Operational QA Program for safety-related modif'ication work, with the following exceptions / clarifications:
(a)
The definition of Class I and Class IE electrical equipment set forth by this standard does not conform to the equipment categories of CNS.-
Electrical items upon which the Operational QA Program is based are included in Table 1 of this policy document and the CNS "Q" List. The scope and applicability of this standard shall necessarily be limited to these defined areas.
(b)
Appropriate requirements for installation, inspection, and tests are defined in job specifications and work instructions developed as a part of the 1
modification work package. It is not intended that separate procedures be established which specifically address the various areas of this g
standard. During the development of work packages, consideration will be given to the areas outlined in Section 2.3, as appropriate.
(c)
The requirements for installation, inspections, verifications, and tests shall be included in the work instructions.
In the development of these instructions, consideration will be given to the guidance provided by Sections 4.0,5.0, and 6.0 of this standard, and appropriate requirements 2-8 Revision 10
l will be incorporated into the instructions. It is not intended that separate procedures be established to specifically address all of the areas referenced.
(d)
Application of the guidance provided by the additional codes and standards listed in Appendix B will be considered to the extent that such codes and standards provide useful and practical guidance for the work being performed. Commitments to the guidance of N45.2.4 shall not include commitments to the guidance of referenced standards.
3.
ANSI N45.2.5-1974 " Supplementary Quality Assurance Requirements for Installation, inspection, and Testing of Structural Concrete and Structural Steel During the Construction Phase of Nuclear Power Plants," and its associated
-l Regulatory Guide 1.94, shall be applicable to the CNS Operational QA Program for safety-related modification work, with the following exceptions / clarifications:
]
1 NOTE
]
With respect to structural concrete, acceptability shall be documented in accordance with the District's Dedication Procedurcsj r hieh-wilFbe-verified-by4ndependent QA audit w
(a)
Appropriate requirements for installation, inspection, and tests will be set forth by job specifications and work instructions developed as a part of 2-9 Revision 10
E l
the modification work package.
It is not intended that separate
~
procedures be established which specifically address the various areas of this standard.
However, in the development of the work package, consideration will be given to the areas outlined in Section 2.2, as appropriate.
(b)
The requirements of control and calibration of measuring and test equipment set forth by this standard shall be applied to all measuring and test equipment used by NPPD or their agents, test laboratories, and contractors.
Such requirements, however, will not be imposed on commercial batch plant facilities. Instrumentation at commercial batch plant facilities will be evaluated by NPG construction management personnel, or their designated representative, to determine that sufficient accuracy can be obtained.
(c)
For small quantities of concrete involved in modification work, all concrete must be purchased from commercial concrete batch plants. For -
these small quantities of concrete, it is unreasonable to expect commercial facilities to shut down normal opera'. ions to provide certified aggregate, cement, admixtures, fly ash, water, etc.. In this respect the qualification tests required by Table A for aggregate; cement, admixtures, fly ash, and pozzolans; water and ice will not be required. Appropriate evaluations will be made to determine that good quality and generally-acceptable materials are used. NPG construction management evaluation, coupled 2-10 Revision 10 y
=-
L i
with slump tests, air entrainment tests, and concrete cylinder strengths, will provide adequate control and qualification of the concrete.
i (d)
Design mixes consistent with, or equivalent to, original requirements will be specified and the results of the cylinder tests will be evaluated by NPG construction management based on the r.~,cptance criteria associated with the original design mix requirements.
(e)
The inspection requirements of Section 4.2 will not generally be performed as the small quantities of concrete involved in modification 1
work will no doubt be mixed using materials already in the batch plant bins. Control of storage of materials would not be practicable.
(f)
If available, appropriate certifications shall be obtained from the concrete supplier which verify the adequacy of truck mixers per the requirements of ACI-304, ASTM C-94. Where certifications are not available, two concrete test cylinders representing the first and last one-third of truck mixer contents shall be taken for evaluation of the mixer truck, over and above the normal concrete cylinders taken to evaluate the in-place
~
concrete. The concrete batch plant facility shall be inspected by NPG construction management and the CNS QA Staff to assure that reasonable controls are being exercised with reference to the inspection guidelines set forth by Section 4.3(1) and (2).
2-11 Revision 10
(g)
Inspection of fills and earthwork will meet the general requirements set forth. The extent to which individual inspection requirements are met will depend upon the nature and scope of the work to be performed, f
(h)
Except for normal batch qualification tests (slump, air content, temperature, and compressive strength) and initial reinforcing steel certifications, the in-process tests required by Table B are generally-applicable to the periodic control which must be exercised with reference to long-term construction type programs. The in-process test requirement of Table B are not considered applicable to short-term modification work as would be required by QA at CNS.
4.
ANSI N45.2.8-1975 " Supplementary Quality Assurance Requirements for Installation, Inspection, and Testing of Mechanical Equipment and Systems for the Construction Phase of Nuclear Power Plants," shall be applicable to the CNS Operational QA Program for safety-related modification work, with the following clarification:
(a)
Where specific design requirements included in this standard ~ or referenced codes and standards are in conflict with original design requirements set forth in the USAR' and other appropriate design-documents, the original design requirements shall govern.
2-12 Revision 10
2.4 Procurement Document Control.
Cooper Nuclear Station Procedures, Nuclear Engineering and Construction Department Procedures, Quality Assurance Plans and Instructions [issfMidIQQilAlifff66&liIi@
are required to define the applicable requirements, design basis methods, and procedures for procurement of spare parts, materials, equipment, and services for essential nuclear systems. These instructions and procedures shall also include provisions for assuring that the necessary quality requirements are incorporated directly into the procurement documents for essential spare parts, material, equipment, and services.
These instructions and procedures shall also include provision for assuring that the necessary records are specified and provided to the District by the supplier.
The basic principles and practices included in these procedures are expected to be applicable to any purchasing activity necessary for operation of the station; however, additional special controls may be necessary for major modification or repair activities.
Procedures covering procurement provide for independent Quality Assurance review of '
essential efsjkl quality commercial grade purchasing documents; QA review and approval of suppliers; and QA Audit of contractor and supplier activities.
RERisiodsChange Orders issued on any procurement document will be subjected to the same review and approval as the original order.
2-13 Revision 10
b
'All procurement documents issued to suppliers of safety-related items or services require.
that the supplier implement a Quality Assurance Program that meets the intent of 10CFR50, Appendix B (with the exception of those suppliers performing all work at Cooper Nuclear Station or in the Columbus Geneml Offices under the District's QA Program). The Quality Assurance Programs submitted by the supplierj will be evaluated '
by NPPD QA to ascertain that they meet the criteria established in 10CFR50, Appendix B. All safety-related suppliers shall appear on the applicable section of the NPPD Suppliers List.
To the maximum extent practicable, the as-built drawings and specifications for Cooper Nuclear Station will be used in procurement of spare parts, material, and replacement parts.
Where necessary, because of design modifications, or where it is necessary or desirable to upgrade quality in replacement parts or material, necessary modifications will be made to drawings and specifications to incorporate requirements for currently appropriate quality level.
These modifications or upgrading of replacement parts will be accomplished in accordancc with approved instructions, procedures, and drawings.
These documents will be subject to required reviews before being implemented, Specific to the ANSI Standard related to this criterion, the following commitment applies:
L 3
2-14 Revision 10
1.
- ANSI N45,2,13-1976 " Quality Assurance Requirements for Control of-Procurement of Items and Services for Nuclear Power Plants," is applicable to the CNS Operational QA Program, with the following clarification:
(a)
It must be acknowledged that equipment and components purchased during the design and construction phase were not purchased on the basis of present-day standards, especially with reference to supplier approval and supplier Quality Assurance Programs. In this respect, replacement parts and spare parts for existing equipment are often limited to
.l sole-source suppliers.
Such replacement parts or spare parts are purchased to appropriate quality standards, verified by;NPPD QA,'to j
maintain an " equal to or better than" condition but_it is not considered J racticable to backfit the requirements of this standard to all such-i suppliers.
'l l
2.5 Instructions. Procedures. and Drawings Quality Assurance activities and other activities which have nuclear safety significance will be prescribed by documented instructions, drawings, and procedures as appropriate and shall be accomplished in accordance with these instructions, procedures 'and-drawings. These instructions will be sufficiently detailed and; explicit so that any-supervisor, inspector, or auditor can, by observation, determine whether or not activities are being satisfactorily accomplished and documented. These documents shall_ include the qualitative and quantitative acceptance criteria necessary to assure satisfactory 2-15 Revision 10-
i'l
-j completion of the test procedure. Those' acceptance criteria shall, where appropriate, require post installation testing prior to returning the component'or system to service.
y
.1 Repair maintenance activities on essential systems are performed in accordance with the Maintenance Work Request process. H.c required docume-Otien for :peeld proce;:;cs are fornrded 10 the CNS QA St ff for revieve dca; vi h :p :!d te;; precedure:; =d '
specid mainten= c prceedure:;.
Document Hierarchy shall be as follows:
Level I:
License Basis Documents Technical Specifications Operating License
" Safety Analysis Report" Updated Safety Analysis Report NRC Correspondence (Commitments and SERs)-
- ]
Quality Assurance Policy Document -
)
2-16 Revision 10 a
-]
Level II:-
Design Specifications and Drawings t
i u: vel 111:
Procedures Administrative Procedures 0
1 a
1 Operational Procedures 1
Work Procedures
-i
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.1.j Level IV:
Policies and Guidelines i
i i
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Nucler Power Orcup Directives -
1 e
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.l
-2.6 pocument Contral Administrative control procedures shall'be established by the Nuclear Power Group (NPG) Col 5.isbuFO., eHEEFO.~ffiss:(CG,O)"ssi.d..~~C66ps.EN6..61&.s.F. Sis 66. 6n~(CN~S) to control
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2-17 Revision 10 i
the identification, indexing, filing, retention, retrieval, and distribution of quality-related records and documents.
Control procedures shall be reviewed and approved by authorized personnel and are distributed to and used at the site of the activity. These procedures shall also ensure that changes to quality-related records and documents receive the same level of review and approval as the original document.
The overall objectives of NPPD document control are to:
a)
Identify those records and documents which are used to control, maintain, modify, or document quality-related activities both at the CGO and at CNS.
b)
Establish an index of quality-related records located at the CGO and at CNS to enable personnel involved in safety-related activities to determine the proper documents to be used in the activity.
c)
Establish a filing system.
d)
Establish periods of retention.
c)
Establish measures to control distribution and revisions.
The CGO Manager of Office Systems Services, CNS station management, and the.
Quality Assurance Division will jointly establish lines of specific responsibility, interfaces, and document control procedures.
1 2-18 Revision 10
=
=
Specific to the ANSI Standard related to this criterion, the following commitment applies:
4 1.
ANSI N45.2.9-1974 " Requirements for Collection', Storage, and Maintenance of.
Quality Assurance Records for Nuclear Power Plants," and its associated Rcgulatory Guide 1.88 shall be applicable to the CNS Operational QA Program, with the following exception / clarification:
(a)
For those design, manufacturing, construction,-and operating records generated prior to implementation of this standard, it is not our intent to backfit the detailed requirements of this standard to those records. All such records, however, have been initially designated for lifetime storage, until specific review dictates otherwise, and will be stored in the record storage facility. Record indexes and filing systems shall be established to permit reasonable identification and retrieval. The records will be stored and preserved per the requirements of Section 6.0 of this standard.
2.7
_Cantrol of Purchased Material. Eauioment. and Services 1
O NPPD receiving inspection instructions provide for determining = that all purchased materials, equipment, and services purchased directly or through a contractor, supplier, ti or subcontractor meet - the requirements specified-on the original ; procurement specifications, such as code,' standards, specifications, dedication, material identification,'
i 2-19 Revision 10
- .4-
i etc, The completed receipt inspection report will become part of the purchase order-package. Procurement documents shall be available at the receiving area to identify the receiving inspections required.'
Nuclear Quality Procedures provide for evaluation of supplier's quality program to determine effectiveness and compliance to the applicable 10CFR50 criteria as part of the supplier selection process. These instructions shall describe the methods and techniques used to evaluate the supplier's Quality Assurance Program.
The QA Division shall re-evaluate the supplier's quality program at intervals consistent with the importance, complexity, and quantity of the item or services to effectively maintain control of quality. Procurement documentation will specify mandatory hold points for witnessing or inspection of purchased materials, equipment, or services, if required by NPPD.
Upon receipt at the station, material, parts, and equipment purchased and identified as
" Essential" or " Quality Commercial Grade" will be placed in a segregated storage area.
.l until all inspections are complete and all required certifications and documentation is.
received.
Items in segregated areas will not be issued,' by the Warehouse, without the writteni permission of the Site Plshi Manager or designee, and then only after proper arrangements have been made to assure that necessary steps will be taken to bring all r
2-20 Revision 10
aspects of the particular item into conformance with normal requirements prior to the system containing components in " Hold" status being considered operable.
Suppliers of essential equipment, if appropriate, shall be required to provide certined documentary evidencc that the material supplied conforms to the purchase document requirements such as material test report, code required test and inspection, documentation, etc. A complete set of documentation required by the procurement document for all essential materials, equipment, and services will be filed at Cooper Nuclear Station.
2.8 Identifical en and _ Control of Parts. Materials. and Compone.on To the maximum extent practicable, activities carried out during operation of the Cooper Nuclear Station will comply with the requirements for identification and ' control of u
materials, parts, and components as set forth in the as-built drawings and specifications for the station. Where special measures are required to assure proper identification of materials, parts, and components, such requirements will be incorporated directly into the procurement documents for such parts and assemblies. Such identifications which i
may include heat numbers, serial numbers, or other means of identification of the item-
)
will be incorporated into the procurement documents to provide means of traceability.
Material received at_ the station (which has not been properly identified) will be.
1 segregated and tagged to indicate a " Hold" status. Except as indicated in Section 2.7 above, such parts will not be issued or used prior to final acceptance. CNS procedures will incorporate requirements necessary to assure that the identification measures are 2 21 Revision 10
properly carried out at the station, that unacceptable items will not be used in essential systems, and that the components to be used in essential systems receive independent verincation of component identity prior to installation.
2.9 Control of Special Processes General maintenance procedures provide for performance of special processes by qualified personnel using qualified and approved procedures. Control procedures provide for QA review, inspection, documentation of activities, and for proper integration of i
QA/QC Inspection. In most cases, the procedures will be prepared only when a specinc d
process is required in the maintenance, repair, or modification'of essential equipment at CNS. These procedures shall also require special processes, such as welding, heat treating, and NDE, to be controlled and performed by qualiGed personnel in accordance with qualined procedures.
l Maintenance modification control methods and Station Operating procedures are reviewed i
by CNS QA personnel ildrififisiksis)eMjsMjalustiphyijidifs?665sijiillincMs. @is This reviews includes verification that necessary codes, standards, quality requirements, I
and acceptance criteria are incorporated to ccatrol special processes within established ;
i limits.
2.10 Insoection 2-22 Revision 10
i Quality Control inspections have been assigned in this policy document to the organization basically responsible for the performance of the activity. A Peer QC Program will be utilized in which QC inspections are normally performed by QC Inspectors who have been selected from within the Nuclear Power Group, and who are many times just as qualified to perform the work as they are to inspect the work. QC personnel will be qualified / certified, and will conduct the QC Program, in accordance -
with NPPD's commitment to ANSI N45.2.6. This conduct of the QC Program will be within the detail established in the CNS Operations Manual, Volume 12.
Quality Assurance Audits /AjsEssmeiiiMEultiatidas and Surveillance of activities such
'l as maintenance, repair and modifications will include direct observation; whereas i
operating functions will be monitored indirectly by observation and examination of l
individual operating personnel and documentation at intervals consistent with-the importance of the activity. Direct QA or QC inspection will also be conducted for activities such as refueling, radiochemistry, and environmental monitoring. Special inspections, such as those requiring qualification to ASNT-TC-1 A, will be contracted to approved suppliers. If direct inspection is impossible, indirect control methods will be specified in the instructions to provide a method of monitoring process methods and equipment. The results of all inspections will be placed in permanent record storage.
Controlling documents pertaining to quality-related activities receive Station Operations Review Committee (SORC) approval to ensure incorporation of appropriate quality requirements. QA is a non-voting member of SORC.
2-23 Revision 10
- Specific to the ANSI Standard related to this criterion, the following commitment applies:
1.
ANSI N45.2.6-1978 "Qualificai.ans of Inspection, Examination, and Testing Personnel for Nuclear Power Plants," and its associated Regulatory Guide 1.58 is applicable to the CNS Operational QA Program, with the following exceptions / clarifications:
(a)
It has always been the belief of NPPD that, in order to be effective, Quality Control must be built into the operation of the plant. With this in mind, Quality Control and test functions performed at-CNS are incorporated directly into the station procedures. Inspection points are then performed and signed off by qualified personnel m t' directly i
performing or supervising the step (s) being inspected., Selection of QC candidates for certification is a function of Station Management.
Actual certification of QC inspectors is the' responsibility of-the QA Division.
(b)
CNS does 'not have the in-house capability to perform nondestructive examinations in accordance with SNT-TC-1 A.
These services are currently contracted to an approved supplier.
Any required.
nondestructive examinations will be: performed by personnel who are qualified and certified per SNT-TC-1A.
2-24 Revision 10 I
2.11 Test Control Each type of test program performed by the station operating group will be defined by written procedures and instructions. These test programs include the preoperational tests, start-up test instructions, operational testing and surveillance testing of structures,-
systems, and components to demonstrate their capability to perform satisfactorily as a i
L U
part of an integrated system. Acceptance tests will be developed for structures, systerns, l
L
'l and components to demonstrate their capability to perform satisfactorily following repairs L
or modificain prior to returning to service. Test procedures will identify the inspector, test performer, date, and data recorder. Each type of acceptance test has individual test l
procedures which include Quality Control provisions, acceptance criteria, and check l
points for observation or checking of important aspects.
These test prccedure 1
prerequisites will include the test instrumentation requirements and ' environmental
.j q
conditions. All Special Test Procedures, $p6diallib6&ldids Maintenance, and Station-'
Operating Procedures are routinely reviewed by SORC, of which QA is a member.
Quality Assurance Audit 57Assissi65hisREstusjl6?is and Surveillance activities will be performed by the Quality Assurauce Staff members to assure 'that tests are being performed in accordance with the requirements of the procedures, that results -are evaluated and compared to the specified acceptance criteria, and that tests are being.
performed by appropriately trained personnel. In addition, test procedures shall specify test requirements and quantitative and qualitative acceptance criteria where appropriate.
2-25 Revision 10
_---------_------_----------..---------------.----------------------.----.---_---------.a
2.12 Control of Measuring and Test Equipment Procedures shall define the requirements of inspection, maintenance, repair and calibration of all tools, gauges, instruments, and other measuring and testing devices which are used in activities which affect quality of safety-related equipment.
Each permanent or temporary installed plant instrument performing an essential fun: tion has been identified and placed on a regularly-scheduled program ofinspection, test, and recalibration. All test and measuring equipment required for calibration of the above equipment will also be placed on a regular program ofinspection, test, and recalibration and will be appropriately tagged. Documented calibration records are reviewed, as -
required, to evaluate calibration performance and frequency, and changes are made as may be necessary.
A Quality Assurance Plan will prescribe the QA functions to be performed relative to the -
calibration program.
Quality Control and Quality Assurance practices require independent checks of calibration activities. Quality Assurance Surveillance performed by the QA Staff members will verify that procedures are being properly followed; that u
adequate records of calibration and testing of mersuring and test equipment are being generated, maintained, and that regularly scheduled adjustments are made' to maintain 1
necessary accuracy. For equipment used to calibrate process equipment, procedures will define action to be taken should regularly-scheduled calibration checks reveal an out of specification condition exists. When inspection, measuring, and test equipment are found to be out of calibration, an evaluation shall be made, and docuuented, of the validity of I
2-26 Revision 10
previous inspection or test results and of the acceptability of items previously inspected or tested. Should the evaluation determine that previous inspection or test results obtained with the affected instrument are unacceptable, Eg6iiE6jiRBMEti6Qgia^iij (ChP) a Nonecafermance Report (NCR) will be issued. 'Eisijg366sinsiitfihs ihscrepancyj Reference and transfer standards, traceable to the Naticnal Institute of l
1 l
Standards and Technology (formerly NBS)) will be maintained at CNS.
l Scheduled and/or unannounced audits or surveillances by the Quality Assurance Staff, the Safety Review and Audit Board, or NPPD management will include review of the calibration program.
]
1 1
2.13 Handlig. Storage. and Shinpine The procedures for procurement and control of essential spare parts, materials, replacement parts, and equipment include the requirements for the control, handling, cleaning, shipping, receiving, and storage of essential parts and material. Quality Assurance Plans and-Instruetions provide for surveillance and audit to assure that procedures are followed and that essential parts and materials are received, inspected, stored, and controlled in such a manner so as to prevent degradation.
Specific to the ANSI Standard relating to this criterion, the following commitment applies:
i l
I 2-27 Revision 10
1.
ANSI N45.2.2-1972 " Packaging, Shipping, Receiving, Storage, and Handling of Items for Nuclear Power Plants," and its associated Regulatory Guide 1.38'is applicable to the CNS Operational QA Program, with the following exceptions /clari6 cations:
(a)
NPPD's QA program is structured to identify' safety-related equipment and provide for designation of packaging, shipping, receiving, storage, and handling requirements for purchased parts and materials. -The classi6 cations of this standard cannot be applied directly to individual-spare parts or subassemblics of the parent equipment. Due to difference in volume, complexity, inspectability, etc., the packaging, shipping, hartdling, and storage requirements of spare parts and subassemblies will necessarily be different from the requirements which may be imposed on the entire component or piece of parent equipment.
(b)
The majority of items purchased for an operating plant consist of-components, subaswmblies, and individual spare parts which could be used in a multitude of different applications. Such items are purchased to the most stringent requirement for their intended use. The volume and characteristics of procurement during the operational phase differ significantly from those purchases made during the design and construction phase. Items requiring special storage protection will be identified on the purchasing _ documents.
Items that must be stored outdoors (equivalent of Level D) and items that must be stored in covered 2-28 Revision 10
but unheated conditions (equivalent of Level C) will be evaluated on an fL individual case basis.
However, it is not considered practicable to l
l l
preclassify individual parts by levels as required by Section 2.7 of this standard. Shipping and packaging requirements for such items will 1
likewise be handled in the procurement documents, as appropriate.
(c)
QA Audits [Ks56sinisngEshisti66i and Surveillances are performed to verify that the requirements of N45.2.2 are met except as noted in (a) and (b) above.
2.14 Insocction. Test. and Operating Status The NPPD status. tagging procedure, already in use throughout the system, has been adapted for use in the Cooper Nuclear Station. Where practical, particular emphasis shall be placed on tagging to prevent unauthorized o;eration or adjustment which could i
endanger the safety of personnel, damage equipment, or invalidate the results of tests already performed. These tags shall indicate abnormal equipment tes: and inspection I
status and reference special instructions for equipment located throughout the Cooper i
Nuclear Station.
'\\
Tagging procedures, where necessary, will require that equipment be tagged and that the associated power supplies, starters, switches and controls on the main control panel are tagged as well, to warn against operation. In some cases, power supplies.will be disconnected and tagged to prevent inadvertent operation. Tagging will be controlled by.
2-29 Revision 10
the Shift Supeivisor by in,uiring that serially numbered tags, obtained from the Control Room, be used for all tagging purposes. Records will be maintained in the Control
. Room to enable operators and shift Supervisors to determine the status of the equipment tagged!
A Temporary Modifications Control Program will be maintained to provide a method for recording the installation and removal of jumpers, fuses, or wire terminal disconnections.
This record will iislude the location, reason, name of person authorizing action, and name of person performing the installatic1.
Requirements for tagging are included in the applicable procedures. Status tat;ging will be verified by audit and surveillance.
J 2.15 Honconformine Materials. Parts. or_. omponents C
Warehouse and maintenance procedures include requirements for the identification and tagging of nonconforming raaterials, parts, or components, (See Section 2.8).
'D1hfjngstiEAstj6if PrbiisniTCAP) The-Noneonformance-Reporting-Progam-This program shall be used by all persons performing operation, maintenance, modification, and quality related functions to record and report:
a)
Deviations from approved procedures; 2-30 Revision' 10 -
ki b)
Nonconforming materials,' parts,'or components received from outside suppliers
. on essential purchase orders; c)
Nonconforming materials, parts, or components within the plant; d)
Nonconforming materials brought on site without following established receiving and inspection procedures; e)
Orders or recommendations to stop work; f)
Reportable occurrences; 1
g)
Any other deficiency which violates the intent of the Quality Assurance Program-and which could have'a significant adverse effect on quality; h)
Deviations which could be reportable under 10CFR21.
A separate report (5UiiAMsjifeifdii@g53Es$id651fj@iiish!M shall be prepared for each nonconformance. The intent of this separate report requirement.is to simplify follow-up, corrective action, and record keeping.
Deficiencici and/or' devia'icas.
identified by QA Staff persennel dall be reported on a Odalify A= ance finding fc=.
The Deficicacy Repea-(DR) Program
]
4
_i 2-31 Revision 10
i J
This program shall ~als6 be used by all persons performing operation, maintenance, modification, and quality related functions to record and report occurrences requiring the performance of analyses and/or corrective ectionj Mvhich dc r.ct meet the threshcid of an NCR.
1 Nonconforming items will be controlled in such a way as to prevent their inadvertent use or installation. Such parts will be reinspected and reviewed for adequacy prior to returning them to the manufacturer, scrapping them, or arranging for them to be i
reworked to conform. Disposition of a nonconforming item will be determined by the i
responsible supervisor in conjunction with the QA Staff. Written reports of decisions to repair or rework essential items will be reviewed and approved in accordance with i
i maintenance and/or design control procedures.
Any decision to reduce requirements to permit use of nonconforming parts, materials, or components in essential systems, will be documented as a nonconformance report and i
will be subject to Station Operations Review Committee (SORC) review and approval.
1 Appropriate design modification documentation will be completed, if required.
Approved Procedures will be utilized for repair and rework of essential parts and equipment. All such rework will be thoroughly documented, including Quality Control and Quality Assurance Surveillance activities, to assure conformance with the requirements of the specifications, procedures, and other controlling documents.
2-32 Revision 10
' Essential equipment classified as scrap will be identified and segregated in such a manner to prevent inadvertent use or installation in an essential system.
The GGO-QA-Department QEl>ipisi6j will issue a quarterly trend report to the Nuc! car Power Group Manager Vi@Haiidi6f3]Ghlisi which may identify adverse trends that -
require corrective action.
f 2.16 Corrective Action NRC Regulations which require formal reporting to the NRC of failures, malfunctions, deficiencies, unusual operating experiences, and deviations which may have a significant effect on quality or safety will be reviewed and evaluated by the Station Operations Review Committee and, where appropriate, by the Safety Review and Audit Board. It will be the responsibility of the Nuclear Group personnel to identify and promptly coiTect all such deficiencies or malfunctions either by improved maintenance, repairs, replacements, or modification. In all cases, the objective and the corrective action will not only be to correct the existing defect or deficiency, but also to include measures to determine cause and prevent recurrence of similar failures. Quality Assurance activities will verify that corrective action is performed in accordance with approved written procedures and that the details of the corrective action are properly documented for the permanent station records.
I A-monthly status report of open NCit's shall be prepared and distributed to:
Wee-President Production 2-33 Revision 10 1
e Nuc!cai Power Gruup Manager ylj{"fjj!d5iiOEs!5sj SRAB Administrater g;u u_.
v~~w=creem=ww=rer: crc rzew:=====i
~--e
=m====u
==:=m=~r:m Divisica "an;ger Nuc! car Engineermg and Construction Divisica Manager Quality Assuranee Divisica Manager Nuclear Support Plant Manager Senior Manager Site Support COO Oaality-Assurance Ksssssissiij Manager C4S-Regulatory Compliance Specialist i
L C-NS-Department Managers 2.17 Ouality Assurance Records All activities having a significant effect on quality and safety will be thoroughly documented, and all such documentation will be incorporated into.the record storage l
system. Procedures will require appropriate physical storage and personnel to maintain 1
a]
these files. Record identification, storage, retrieval, access, control, retention, and 1
safeguarding'of all quality-related records associated with CNS will be in accordance -
.'I 1
with approved procedures. Records to be maintained include all records accumulated -
during engineering and construction and those records generated during' station operation, maintenance,- and modification as dhf' ed in the CNS Technical Specifications. ~ These
~
m g
records shall also include qualification of personnel, equipment, and procedures.
Inspection and test records shall identify the inspector, data recorder, method of.
2-34 Revision 10-
i observation, results, acceptance, and all nonconformance reports issued to document noted deficiencies.
CNS and/or Columbus General Office personnel will be allowed to maintain active.
working files at their work stations. The time frame for submitting these records to record storage facilities will be determined by their respective administrative procedures.
Administrative procedures shall provide for methods for changing records that provide clear identification of the change and must be initialed and dated by the person making -
the change and by persons authorized to approve the changes.
i The program will include Audits of record storage facilities to' assure that the procedures and controls are properly implemented. The CGO Manager of Office Systems Services and CNS station management will prepare detailed procedures for receiving records into the facilities and for making decisions on removal and disposal of outdated or superseded j
records.
Refer to Section 2.6 " Document Control" for the commitment to ANSI N45.2.9.
2Property "ANSI code" (as page type) with input value "ANSI N45.2.9.</br></br>2" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process..18 Audits Scheduled and unscheduled audits will be performed to verify compliance to CNS QA Program requirements and to determine the effectiveness of the area audited. Quality i
Assurance Plans for each functional area of station operating activities have been or will be prepared. These QA Plans identify the nature and extent of Quality Assurance audit 2-35 Revision 10-
activities to be performed by QA Personnel or under the direction of management. Audit responsibilities are assigned to the Division Manager of Qaality Assurance. Audits performed under this direction (working with the Safety Review and Audit Board (SRAB) as referenced in Section 3.5) will be conducted according to the QA Plans to verify compliance with the Quality Assurance Program.
Audits shall be performed in accordance with written instructions or checklists and conducted by trained personnel not directly responsible for areas being audited. NPPD Management may request audits of specific activities of particular concern to them. However, all such internal audits will be coordinated to avoid interference with the operating activities at the station. Upon completion of the audit, a formal report will be prepared and transmitted to the organization audited which will include an evaluation statement regarding the program's effectiveness. All audit findings identified will be documented and appropriate-feHow-up aetion-will be taken to assure that-correetive-eetion has been implemented. Ente [Ed]5fy (fs@alfhi6g@niW6[UsBkipaiid[ disp 6)iti65} Follow-up action, including reaudits to verify corrective action, shall be fully documented.
l Specific to the ANSI Standards relating to this criterion, the following commitments apply:
1.
ANSI N45.2.12-1977 " Requirements for Auditing of Quality Assurance Programs for Nuclear Power Plants," and its associated Regulatory Guide 1.144, is applicable to the CNS Operational QA Program, and to the Supplier Audit Program.
i 2-36 Revision 10
.1 l
J
2.
Section 4.0 of ANSI N18.71972 " Administrative Controls for Nuclear Power.
Plants," will be used as a guide for scheduling and conducting audits.
3.
The frequency of audits will be in accordance with Regulatory Guide 1.33,
" Quality Assurance Program itequirements (Operation)".
2.19 Additional ANSI Standarda ANSI Standards applicable to the CNS QA Program for Operation, not directly related to the preceding sections, are discussed in this section:
1.
ANSI N45.2.1-1973 " Cleaning of Fluid Systems-and Associated Components During Construction Phase of Nuclear Power Plants," and its associated Regulatory Guide 1,37, is applicable to the CNS Operational QA Program, with the following exceptions / clarifications:
(a)
Cleaning requirements for almost all maintenance, repair, and modification work will be considered as a part of the overall job requirements.
In this respect, detailed cleaning procedures will not.
'I generally be prepared as separate documents. Necessary requirements, consistent with the scope of the work, will be included as a part of the-overall work instructions. System cleanness is controlled at CNS by the following methods:
i 2-37 Itevision 10
. y J
e r
(1)
Parts and ' components are checked for cleanness during receipt inspection and :
' stored in a manner that will ensure adequate levels of cleannes's arelbeing -
maintained.-
(2).
Work instruction will be reviewed by Quality Control to assure that adequate cleaning and access controls are incorporated'into work instruction and associated L
[
safety-related activities.
(3)
Parts and components are inspected for cleanness prior to installation' in accordance with CNS maintenance procedures.
(4)
Work areas are maintained at a cleanliness level appropriate to'the maintenance =
or modification activity being performed.
e (5)
Quality Control iH(Supi@s6fy or Engiraring Inspections before,- during, and l
.i after. safety-related maintenance or modification activities address system 1
cleanness.
y zi H
(6)
Random QA Audit [K@pQEjidis@ and Surveillance of safety-related maintenance or modification activities requires verification of part, component, and system cleanness.'
.i
)
1 q
2-38 Revision 10
- l
(b)
For cleanness classiDeations where the scope of plant modification work is such as to make application of the guidance provided by this standard I
practicable, the cleanness classifications and requirements thereof shall be evaluated and applied, as appropriate, as a part of the overall work requirements.
(c)
For most modification or maintenance work, however, involving only small portions or individual components of larger systems, it -is not considered practicable to conduct cleanness tests with ASTM Ell-70 Series. Appropriate cleanness will be maintained during the work and preoperational Hushing will be conducted, consistent with the scope of the work performed and the original design requirements. Controlling the i
parts and ' components and the work area has provided CNS with reasonable levels of assurance that system cleanness will be maintained.
In addition to the above, the' Water Chemistry Department routinely samples and tests for system cleanliness, corrosion, crud buildup, etc.
2.
ANSI N45.2.3-1973 " Housekeeping During the Construction Phase'of Nuclear Power Plants," and its associated Regulatory Guide 1.39, is applicable to the CNS Operational QA Program, with the following exceptions / clarifications:
'(a)
The plant has been divided in zones for fire protection and security purposes. The zone designated for cleanness in the ANSI Standard are -
2-39 Revision 10
primarily intended for control or work during construction of the plant.
Therefore, the CNS facilities will not be classified by the zones designated in the Standard general housekeeping rules. Limitations on eating, drinking, and smoking are already provided in existing CNS procedures.
Where special cleanliness controls, tool, and material accountability are required for particular types of work, temporary clean areas will be designated and defined in the procedures hhdy6rk }issksjes for accomplishing the work.
(b)
Fire protection and prevention will be provided in accordance with NPPD evaluation of the CNS fire protection system as required by NRC j
regulations.
(c)
Station procedures have been reviewed to determine the need 'for R
particular cleanness, housekeeping, and control provisions.
Wh'ere indicated, procedures have been revised to incorporate such provisions, 4
i using the guidance of ANSI N45.2.3.
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3.0 ORGANIZATION AND RESPONSIBILITIFE Nebraska Public Power District is solely responsible for the operation of the Cooper Nuclear Station and will fulfill the objectives set forth in the Quality Assurance Program for Operation through its own organization and by contract with qualified contractors and consultants.
3.1 General The overall Quality Assurance Program for Operation shall be conducted in accordance with the-three-dtvisions-ef--responsibility-whieh-provides-4cr Quality Control, independent Quality-Assurance Surveillance;-and-Quality A=urance Audits: (6jii lj9)l{jf]is@hjibilij$W6(P&f6fnjipeQ6dy@j{@yiM{jf@jyi/(pijegripp pverfiMQGslij Mssiliahes)XiidijfdiidjQiialijjMsisisin'sdt]
Table 2 defines the f6ilf three levels of QA as they are to be implemented for station operation and also shows the comparison with similar principles which shall apply to nuclear fuel procurement and any future major engineering and construction activities for the Cooper Nuclear Station.
It is intended that clearly separate lines of responsibility be maintained between those responsible for the operation of Cooper Nuclear Station and those responsible for -
3-1 Revision 10
auditing to verify that all quality and licensing requirements are consistently being met.
QA responsibilities will vary depending upon the type of activity involved (See Section 4.1.3). Additional details on individual QA responsibilities are given in the paragraphs which follow, together with additional explanation of the interrelationships between the various supervisors and managers involved.
3.2 Nuclear Power Group Management 3.2.1 Vice President - Production The Vice President - Production is the responsible executive officer for all CNS Quality Assurance-related activities. He may delegate responsibility to the Nuclear-PoweeGroup-Manager MRI?!@idp5EN6)1 sat as in 3.2.2 below.
3.2.2
-Nuclear Pawer-Grom>-Manager VicFPissidsntTNd61Fg As delegated by the Vice President - Production, this responsibility includes the Quality Assurance requirements governing those structures, systems, and components-that prevent or mitigate the consequences of postulated accidents that could cause undue risk to the health and safety of the public. Pertinent activities include designing, purchasing, fabrication, handling, shipping, storing, cleaning, erecting, installing, inspecting, testing, operating, maintaining, repairing, refueling, in-service inspection and modifications that are associated with Cooper Nuclear Station.
3-2 Revision 10
The responsibility and authority over the Safety Review and Audit Board has been delegated to the Nuc! car Power Group M=ager ygPipd6(MN6dsu. The Nuc! car Power Orcup M=ager yJs!PiiindsiiGNsc@ reserves the authority to conduct, or order the auditing or monitoring of any operations activity, at any time, to ascertain the effectiveness of the overall QA Program and to determine that all aspects of the QA Program are being complied with.
3.2.3 Division Manager. Ouality Assurance The Division Manager of Quality Assurance, a member of the executive staff, reporting to the Nuelcar Power Orcup Manager Mi2EPfisidsii@;NGE15H, shall have the responsibility and authority for administrating and maintaining a Quality Assurance Program for Operation which is in accordance with 10CFR50, Appendix B. ' Inherent
~
in this responsibility is the authority to accept or reject any or all work, materials or equipment associated with Cooper Nuclear Station and Columbus GGO. The Division Manager of Quality Assurance shall direct the preparation of plans and instructions for.
u defining the Quality Assurance functions associated with Cooper Nuclear Station to ensure that such activities are conducted in accordance with the Operating License and appended Technical Specifications. He shall also approve all plans and instruetiens pf6sddisi for defining and auditing the safety-related activities within the Cooper Nuclear Station and General Office. ' The actual audit functions to be performed are defined more completely by the body of Nuclear Quali.ty Procedures-Quality 1
Assuranee4nstreetions, and phal;ity[Nssdisiics Plans required by Section'4.0 of this
]
policy document. He shall also have direct responsibility for evaluating suppliers of l
)
- !I l
l-3-3 Revision 10 s
s i
nuclear safety-related equipment, materials, and spare parts and for auditing the QA/QC activities of such suppliers.
The Division Manager of Quality Assurance and Staff shall have the necessary organizational freedom and access within Columbus GGO and Cooper Nuclear Station to institute the necessary Quality Assurance requirements, identify problems, and pursue prompt corrective action.
Figure 1 outlines the QA Division functional organization.
The Division Manager of Quality Assurance shall monitor the Quality Assurance activities to the extent necessary for assuring compliance with the program. He shall review the effectiveness of the Quality Assurance Program with the Noelear-Power Group-Manager Viss P(csidstINuslusi on a regular basis. In addition, the Division Manager of QA has a direct line of communication with the President and C.E.O. He shall serve as a member of the Safety Review and Audit 130ard and provide additional QA Personnel to participate in SRA13 activities when requested.
NPPD Quality Assurance Staff, under the direction of the Division Manager of Quality.
Assurance, shall have the responsibility and authority for implementation and ongoing development of the Quality Assurance Program for Operations. In addition,'it shall be the responsibility of the Quality Assurance. Division to monitor the interface between the-Nm4 ear-Operationand-Nuelear-Engineering-and-Gon-struction-Division siljN6cleaf;Pis!f6GioupWiVisibni to ensure that plant modification and repairs i
receive the proper desigereviewmand-approvale 'rifas5E[nstT60eisity 3-4 Revision 10
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.i
As shown in Table 2, he shall have responsibility for accomplishment of third level QA Audits and shall obtain assistance and special expertise when necessary. to complete such audits effectively.
3.2.4 Ouality Assurance 065sti6ds Manager-C-NS The GNS Quality Assurance OieralI6hi Manage, reporting to the Division Manager l
of Quality Assurance, shall have the respcasibility and authority-for-imp!cmenting-and maintaining the Quality-Assurance-Program for Operatien-at-GNS. IIe shall-also be responsible f6r and have the authority to perform, direct, or coordinate QA Surveillance and Audit activities within Cooper Nuclear Station. -to %ejs 55tiVitiesTsill determine if conformance with %i[P61icf[lMi@stij NPPD Quality Assuranee-Manual and applicable federal regulations as-defined-in the NPPD QA-Manual are being maintained. The GNS QA ppsstiohs Manager shall advise and assist the Seni6r Mship,6nien@s6dds! Gile-Manager and itisli' his staff in all matters which affect the quality of the station. Similarly, he shall advise and assist all station personnel in matters regarding Quality Assurance and Quality Control.' The GNS-QA Dji6 rations Manager shall designate members of the GNS QA Ops [sii6hj Staff {
upon requesti to provide training and instruction programs to enable CNS personnel to effectively execute the District QA Program 5[fiftjjily. The GNS QA D@ti6ds Manager is also responsible for monitoring of open audit items and interface with NRC -
during inspections at CNS. In addition, he shall also be responsible to verify that solutions to safety-related problems have been implemented and to perform scheduled audits of those activities lhted-in Section 4.1.3 cn an announced basis. Id6hlifi6d^iij 3-5 Revision 10
QAiPlssi.
Additional specific duties shall be. defined in the Nuclear Quality Procedurest Quality Assurance Instructiefe and QdilifylXsiGi~ sed Plans issued in r
accordance with Section 4.0 of this Policy Document. The C-NS QA Q@dli6iij -
Manager or designee shall also serve as a non-voting member of the Station Operating Review Committee (SORC).
The GNS QA OpsdiiB6s Manager and Staff will observe operations, maintenance, in-service inspection, special processes, repair or modifications, and other safety-related activities covered by the Quality Assurance Program, and te recommend that work stop when such activity, in their opinion, does not comply with approved controlling documents. The Site Riijii Manager or designee is responsible to set-en s'isluits that recommendation and actually stop work unless it is determined such stoppage would result in a violation of the Technical Specification or other approved documents governing station operation or whether there are overriding considerations of safety involved.
i The GNS QA O@rkti6iti Manager will provide for a coordination function for QC activities at CNS.
This includes reviews of inspector certifications and performance and the establishment of a training program. The function will also provide the communication path for the resolution of QC Inspector concerns.
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t 3.2.5 Ouality Assurance XWhihu Mananer -C-GO
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1 The GenerabOmee Quality Assurance hiiksijMt Manager, reporting to the Division Manager of Quality Assurance, shall have the responsibility and authority for implementing and maintaining the Quality Assurance Pragmm within the COO.
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I 3 Revision 10
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Manager and Staff shall have the responsibility for providing guidance to the CCO Muc! car Divisions _NPGiji.siidshst in all matters affecting quality shd~lis.if5 a
6p_sist.f6h?6fithirp~lihi. They shall also establish and implement the program for
.~~
evaluating suppliers for safety-related equipment, materials, spare parts, and services.
They shd! also be responsible to perform scheduled sureci!!=ces within the Ocacral Of5cc =d verify that corrective action-has been impicmented.
The GGO QA Dijisi6h jK5EssdH{ M=ager shall establish a program for'QA review.
of the design / engineering function in the CCO, includiny, configuration management.
Additional duties are defined in the Nuclear Quality Procedures-End Quality Assurance lastructions, and Plans.
The General Office Quality Assurance ^ssssihisht Manager is responsible for interfacinje along with4hc Divisica M=ager of QA, with NRC inspections E6ik!66tsd WithisWarib.bi*areastbE._tlis_?NPG. at the Ocacral Office. In addition, he lh..E.. T. A.
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s AsissisishiMphijii shall also provide for training and instruction programs to enable General Offtee QA"fss5isinsnj personnel to effectively execute the District Quality Assurance Program. Unless otherwise provided for in writing,-the Ocacral Offtee Quality 4rssurance Manager sha!! act for-the Division M=ager of Qaality Assuranee in-his absence.
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'1 I
i 3-8 Revision 10
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3.2.6 Ouality Assurance Supervisors The Quality Assurance Supervisors report to the applicable QA Manager and are responsible for the performance of work activities assigned. They are responsible to direct the performance of QA activities, and to identify any condition adverse to quality to the appropriate QA Manager. The QA Supenisors are responsible for the continued maintenance and upgrading of QA Program Documents.
3.2.7 Ouality Assurance Staff Ocneral Office Oaality-Aswranee, Staff m m _ __i ncc__ n..asa:...
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s aaw uwnwsus vi s sww yu 6y asaauaunsw u uras as a vw ava p asaavaw 6v uaaa a 6 ua s sa uu v aw the Ocacral Office Quality Assurance Manager in all-matters ethich could affeet-the Quality Assurance activitics within the Genera! Office. This includes advising and assisting Cencral Office personnel in all matters regarding Quality-Assuranee; verifiention-that soluticas 10 safety related prob!cm3 have been implemented, and for the performanee-of audits and surveillances of escrk activitics vithin-the Ocacral-Office on an announced or unannounced basis.
3-9 Revision 10
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properly inebded; =d devebpmen: =d impkmen:::ica cf Sc QA engineering' Ame:ica.
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A The C-NS Quality Assurance Staff shall be responsible to assist and advise the CNS.
Quality Assurance Supervisors in all matters affecting the quality of the station. These duties include.A proce ure pmpara ion p.,wv.rws-_fo_rm_an_ce o....fperform.;ng QA. activit.ies within d
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-~g all station _P personnel in all 1~ v -
matters 'regarding Quality' Assurance and Quality Control; verify Esti{ifiti6n that solutions to safety-related problems have been implemented; d perform p.. fgmance n
an er 6f audits /a55ssimsin$yfi165ti6ns siid surveillances of work activities within CNS @
krt.l_iE_GenhisllOffiEs on an announced or unannounced basis.. Additional duties shall be as defined in the Nuclear Quality Procedures, @ Quality Assurance Plans. rend Instrueticas issued in accord =cc with Sectica 4.0 of thiepolicy document.
Disagreements or differences of opinion on Quality Assurance matters are expec.ted to -
be documented and resolved jointly by both the CNS =d C=cral Office Quality Assurance Staff and appropriate CNS or General Office supervisory personnel. Where such resolution. is not achieved within a reasonable period of time, unresolved 3-10 Revision 10 -
differences shall be promptly reported to the appropriate Quality Assurance Manager for resolotion jointly with the Division Manager of Quality Assurance and the other respective $5_16_fM._EisiEiffjis.is0H651) Division-Managere Site-Manager ar-Plant r
Manager:
Seeretarv4o4hc Division Manager of-GA The Secretary-to-the-Division-Manager of QA shall-be-responsible-for-edministering and-doeu menting-the-controHed-QA-program-doeument-distribution.
Additional specifie-<luties-shah-be-as-defined-in-the-Nuelear-Quality Procedures, Quality Assuranee-Instructions, and-Quality-Assuranee-Plans issued-in-aeeordance-with Seetion-4-0-of-this-policy-deeument-3.2.8 Division Manager - Nu_qlear Engineering and Construction The Division Manager of Nuclear Engineering and Construction'under the direction of the Nuelear-Power-Group-Manager yI66lPf651dsiENii5lisi shall provide technical assistance for plant modification activities at Cooper Nuclear Station. Those Quality Assurance activities associated with such modifications will be conducted in :
accordance with the CNS Quality Assurance Program for Operations. These activities will be audited periodically by Quality Assurance Staff and quality-related problems.
shall be identified and reported to appropriate levels of management for resolution.
The Quality Assurance Staff will perform the necessary follow-up action to assure that-corrective action is implemented in a timely manner.
3-11 Revision 10
i l
i l
K2.9 N 66f# F F SBl: M E si E f For those aspects of Fuel Management QA covered by the QA Program, the Nuclear Fuel Manager, under the direction of the Division Manager of Nuclear Engineering.
and Construction, shall be responsible to furnish technical assistance as required to the Plant Manager and the QA Staff. Such assistance shall not replace or supersede the formal audits.
3.2.9 Site Manager The Site Manager-and-his-staff, under the direction of the Naelear-Power-Group Manager-WRCPissiddifl"QIselEs,-shall be responeibic and hawHhe-authority for assuring that-Quality A:;suranee-eetivitic:;, as defmed by thi:; and other approved QA-Program documcats-are-complied viith.
Some - of-these-responsibilities-ere delegated to CNS-management personnel and include Quality-Gontrol and Inspection femetionuts defined 4n-Tabic 2. Se actual functions to be performed shalH>eslermed in-lower-tier-doemnents-seeh as NQPs, QAPs, NPO Directives, etc.
3.2.10 Plant Manager 3-12 Revision 10
The Plant Manager, under the direction of the Site Manager VibEPfssidsntMpalEE, shall regularly review station engineering, operation, radiological, and maintenance activities for the purpose of keeping abreast of significant quality activities.
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EstiVitiEs'rsisibd'lt6lNusisHlSafejpj 3.2A412 Senior Manager - Site Suonort The Senior Manager - Site Support, under the direction of the Site-Manager yip (
Pr6sidenGNtikpi, shall regularly review station security, training, and warehousing 1
activities for the purpose of keeping abreast of significant quality activities.
l 1
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i 4
3.2.+213 Division Manager - Nuclear Suonort j
j 1
1 The Division Manager of Nuclear Support, under the direction of the Nuelear-Power Group-Manager MiddlyjsidenQ Ndelski, shall be responsible and have the authority for assuring that activities under his control are conducted in accordance with this QA Program. Rit-ineludes but is sot-limited-to-timely respon:;cs to QA Divi:;ica Audit-and-Surveillance fmdingsemi-implementatica of appropriate-correetive actions.
3-13 Revision 10
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3.2A31]
ColuhiS5FassEiil'Offi2EfCGol Deoartment Managers
- CGO Departmental Managers report to either 'the : Division' Manager - Nuclear Engineering and Construction or the Division Manager - Nuclear Support as described -
in the USAR and are responsible for implementation of QA Program objectives.within'-
their area of responsibility.
3.2A415 C66fEFN5ElisFSniilsifCNS) Deoartment Managers CNS departmental managers;-ehher-directly or indirectly, rsport to lhe Pir.nt Mra.ager
/
atdeseribed-in-the'GNS4JSAR-end are responsible for implementation of QA Program '
'i a
objectives within their area of responsibility.
3.3 Cooner Nuclear Staticn Personnel
^l The operational duties and responsibilities of the Cooper Nuclear Station personnel are described in the CNS Procedures Manual, Reference 7.5; In addition, the Cooper:
Nuclear Station personnel are assigned Quality Control and; inspection functions.-
Station personnel, under the direction of the Ghe Rjsi@ Manager Rths}shl6[Migsj 6f SitRSiij@63 and his staff, are responsible for assuring that the station is tested, operated, maintained, and modified in accordance with approved plans and procedures.
3-14 Revision 10
3.4 CGO Personnel The duties and responsibilities of CGO personnel are described herein and in the appropriate implementing documents.
These documents address the CGO responsibility for such items as design, procurement, modification, and licensing.
Reporting through department and division managers described previously, theirs is the first-line responsibility for implementing this program in the CGO.
3.5 Safety Review and Audit Board T.hx<., e.ySa. f..
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ssv,i_ew & a._n_ _ u vg-ar_(S._RA. ;B.1,,,.,7.
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~ sign. ate.,.~c..t.i.vt es:
n iew an a.u i
- m... r...m operation of the plant i:; consistent veith company policy and rule:;, approved operating proeedwes, and operating license-provisions; reviev, import =: proposed plant changes, tests, =d procedures; verify that licensec events are promptly investigated afecorrected in a maaner vehich reducca the probability of recerence of sucheents; and de:cet trends vshich may not be apparent to a day to day observer.
Specific duties and responsibilities of SRAB, including auditing, are identified in th] -
Reference 7.14, CNS Radiological Technical Specifications @feshhj2d4), ed the SRAB Reference Manual.
3-15 Revision 10
-i 3.6 Station Operations Review Committee The Station Operations Review Committee (SORC) has been established to advise the ~
i Plant Manager in all matters regarding operational safety.
Specific duties and responsibilities of SORC are identified in Reference 7.14, CNS Radiologier' Technical Specifications.
I 3.7 Outside Suppliers. Contractors. Subcontractors. and Consultants During L 4fe of Cooper Nuclear Station, it will be occasionally necessary to obtain assistance from outside suppliers and contractors. At all times, these outside suppliers, contractors, and consultants will work under the direction of the NPPD organization?
having primary responsibility for the particular work being performed. In those instances in which outside suppliers or contractors merely furnish personnel to augment the normal station or-CGO staff for 'particular activities, such outside-contractor personne1 shall be required to perform their work in accordance with the CNS Quality Assurance Documents and other appropriate CNS procedures and i
instructions.
In those instances in which ' outside. suppliers,' contractor's, and' a
subcontractors are assigned primary responsibility for a particular activity, such outside contractor shall be required to maintain a Quality Assurance and Quality Control; j
Program and organization appropriate to the work to be performed. - All' suppliers,-
3-16 Revision 10
. contractors, and consultants performing work classified as essential shall be maintained on the appropriate section of the CNS Approved Suppliers List. Selection of outside suppliers or contractors shall require the active participation of the Quality Assurance Division in evaluating and approving their Quality Assurance Program.atul-ftng.
i the-proeurement-documents-prior to awardiftg-the contrad--
In every instance in which outside contractors have responsibility for work at CNS on safety-related nuclear systems, they shall be contractually required to work to.
procedures approved by the District's Station Operations Review Committee.
Recognized standards or existing proprietary procedures may be used, but they must be specifically invoked in writing and clearly identified as to their applicability to the CNS work.
In addition, any outside contractor performing work at Cooper Nuclear Station under their own quality assurance program shall be contractually required to prepare, prior to performing the work, a Project QA Plan specific to the work' to be performed at the Station.
Contractors and consultants performing safety-related work under the District's Quality Assurance Program shall be contractually required to perform the work under District supervision and in, accordance with the CNS. Quality Assurance' Program for Operation.
District personnel responsible for such work shall assure that contractor / consultant personnel are qualified to do the work and have been provided 1
formal instruction in quality assurance.
Additionally, any calibrated tools and'
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3-17 Revision 10
'l
equipment provided by the contractor shall be recalibrated at Cooper Nuclear Station -
or by a District approved source, prior to use.
If any portion of work on safety-related nuclear systems is to be subcontracted, the prime contractor shall impose the appropriate QA requirements on the subcontractor.
NPPD QA shall have direct access to and communication with the contractor's s
personnel at all levels, both at their home office and in the field.
Prior to performing' work at Cooper Nuclear Station which affects safety-related equipment, outside suppliers, contractors, consultants, and selected representatives from the NPPD Nuclear Operation and Nuclear Engineering and Construction Divisions shall jointly develop and enforce written agreements and/or procedures which clearly define the limits of the work; interface between contractor and station personnel; status and custody tagging procedures; contractor personnel dosimetry; and any other aspects which bear on station or personnel security and safety. Such' agreements shall be reviewed by the Quality Assurance Division to ensure compliance with applicable Quality Assurance Program requirements.
At all times when outside suppliers, contractors, and consultants are obtained to assist in the execution of this QA program, the responsibility for effectiveness of these--
support organizations activities will remain with NPPD.
t 3-18 Revision 10
g i
4.0 OUALITY ASSURANCE DOCUMENTS The CNS Quality Assurance Program is defined by written policies, procedures, plans i
and instructions which shall be implemented throughout the operating life of the j
station.
4.1 NPPD Internal Documents Work procedures are based on the requirements of the Quality Assurance Program.
q Preparation and maintenance of basic work procedures is performed by engineering and operating groups, separately from the Nuclear Quality Procedures (sijd QA Plans, and4nstreetions. Mandatory QA/QC checkpoints shall be incorporated directly in or attached to, the work procedures to facilitate coordination between the specific work activity and the Quality Control function. It is not the intent to include the preparation J
of basic work procedures under the responsibility of QA, nor is it the intent to incorporate basic work procedures into the QA Program Documents.
Work precedures, however, sha!! be reviewed by Quality Assurance for proper i
implementation of the QA Program objectives.
J The format-andentent of NQPs, QAP3, and QAls sha!! be as speciCed by a Qaality Assuranee Araetion: Significant changes IO{Woifff666ddi%5iid[QN(Ri6gid@
D666nienf. tall be reviewed and approved by the same levels of management as for the original document. Each change, when approved and issued, shall be distributed through a controlled distribution system.
4-1 Revision 10
Particular circumstances may occur while some work is in progress, which necessitates a change to an approved work procedure. When such circumstances arise, the changes must be authorized per procedure. The written record shall clearly show the nature and extent of the change and the reason for requiring such change.
4.1.1 Ouality Control Insoection I
The Quality Control Inspection function shall be performed by individual (s) other than those who are actually performing the step (s) being inspected or who are providing direct, hands-on, at-the-job supervision. The Cooper Nuclear Station management, as part of l.i.s their normal management function, is. are responsible for iMplsss5 Elf.6~ri m
preparation of the Quality Control requirements of the Peer QC program] however, 1
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.r.at. ions Manager is responsible to e. _staMg..siic.->.hg.,. p.e.y,ye..:.:..is t e proced+u%;n v
+
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w (TheGNS QA -
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fo,r. reviev. and-seeept eentrel-methods -.de_ sign,at.io..n... o..f. : sp.e._cific,. k,a_ct.,t.ies_;wh+ich, two.. r,
ivi_
requireingpect,ionjp,c,..,,ia, g,..,g, ; pr;^r t^ imp,.cmentattorw and also j
mg g n ne g t
i includes provisions for:
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managementrshall verify that-adequate Quality-Gentrol inspections are-incorporated j
direetly-in or-attached to, the work-procedures and shall periodically-inspect work r
performance to assure thaHhe-proceditres containing Quality Control inspections are being-followed. The OC Program-shall-edentify the specific work whieh-is to bc subjected to inspection cr verifieatiomend shall provide in detail-the c!cments cf work to-be4nspeeted which include:
4-2 Revision 10
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1.
Identity of the inspector or data recorder.
-2.
Type ofinspection or verification.
3.
Results (data to be recorded).
4.
Acceptance (qualitative or quantitative) criteria.
5.
Method of disposition of unsatisfactory inspection results.
6.
Reporting requirements.
In addition, clear instructions shall be given regarding the timing, frequency or scheduling, and notification requirements for such inspections so as to obtain maximum effectiveness and to minimize delays in completion of the work.
It must be recognized that certain. work, particularly in nonroutine maintenance or repair, cannot be anticipated. Therefore, procedures and Quality Control Inspection requirements cannot be prepared until a particular problem has been ' detected and -
evaluated.
Routine maintenance and repair of essential systems and components generally requires _
performance of a complete or partial Surveillance Procedure prior to placing the.
system back in service. This type of QC (actual performance or functional testing) 4-3' Revision 10
L following completion of work is considered a unique advantage on an operating facility. Such surveillance testing may be performed by the individuals who performed the maintenance activity. Records of the surveillance will be reviewed by the system engineer or other supervisory / management personnel.
l l
4.1.2 Nuclear Ouality Procedures (NOP) 1 l
The Quality Assurance staff shall prepare NQPs approved by the Division Manager of Quality Assurance and the Nuelear42 ewer 43rouWanager yids Prbsideist3%idleM.
As described in Section 1.5 of this documert, NQPs define Quality Assurance 1
l activities and responsibilities which cross divisional boundaries. When approved, NQPs become a part of the CNS Quality Assurance Program for Operation.
44.3 Oualit y-Assurance 4nstructions40All The-Quality-Assurance 6taff-shall-ptepare QAhapproved+y-the-DivisiefFManager-of Quality-Assuranee-As-previously-described-in-Seetion-Ir5-of-this-documentWAls define-QA-division-work-aetivities-whielakt-not-erosulivisional-boundaries-When approved;-QAls-shall-beeongrt-of-the-GNS-Quality-Assuranee-Program-for Operathm-l l
l l
l 4-4 Revision 10
E l
1 24.1.43 Ouality Assurance Plans (OAP)
A QAP) shall be developed for each functional area defining the scope of the QA-program. Goneurrea; with the pre;xratica of wad pnxedure:;, and4uring c;xtations er :nainicaance activitics, Quality A:;surance Staff shd! devdap QAPs as needed. As described in Section 1.5 of this document, these QA Plans wHl outline specific Quality.
Assurance activities Eid gdii6fal eijisd@di6iij6fyiEM5filisijiiitinhjid]sipisdWn[tisj r
ths^QKPfogisisj and shall become a part of the CNS Quality Assurance Program for Operation. Distribution of these Plans will be to those individuals who are responsible for that particular activity.
The format and content of QAPs shall be specified in a QAl Ng to provide uniformity and to assure that each plan is complete and adequate for the intended purpose.
The QAPs shall be prepared by the Quality Assurance Staff and shall be reviewed and approved by the Division Manager of Quality Assurance. In addition, when significant changes have been made to these documents, the QAP will be routed to siffsffsl@ -
@@@M#ypsn[@M6sl the-following for review' and commentt)
Nuclear Power-Group-Manager L
L S!!c Manager L
4-5 Revision-10
3.
Pi=: M=cger.
Senior M=c.ger of Site Support Division !!=cger Nuclect Engincering =d Construction t
' N Division M=cger Nuc!carSupper:
The QAPs shn!! define the pecific werk vehich is to bc =bjected ic Q=lity Assuranee revieve, =rveil!=ce, and =di:, =d the n=nce in yh.ich =ch revieve, =recil!=ce, and audit is to be imp!;mented.
e v c glt :
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% e.y Checkh,sts dese.s.... u.<,:~hw s
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. _ur._vei_a. n_c_e r,:...-_. g _n _e_m.e_s s ah ll be prepared u
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as described by QAls HQ@ after reviewing the work procedures. describing the QA Suracillance or QA Audit guidelines.
a)
Qpality Assurance Surveillance The - Quality Assurance Surveillance function is intended to provide an-independent verification, on a continuing basis, that work is being performed in accordance with the requirements of the-controlling documents.
Such.
surveillances may be performancei ased or compliance oriented depending on the -
b nature of the function being evaluated. The Quality Assurance Surveillance -
activities are not intended to duplicate QC Inspection activities, however, 4-6 Revision 10 y
duplication may occur, in the effort to satisfy both Quality Assurance Surveillance -
and Quality Control requirements.
Thc. abjectives of Quality Assurance Surveillance are to verify that the Quality Control Inspection Program is being effectively implemented; that personnel performing Quality functions are properly qualified; that adequate information is recorded to provide a complete and accurate quality history; and that deficiencies are identified, corrected, recorded, and corrective action is taken to prevent recurrence.
This philosophy shall be taken into account in developing the checklists as guidance for the conduct of Quality Assurance Surveillance activities.
QA Surveillance shall be as prescribed in NQPs iUid, QAPs, and QMs.
The QA checklists shall identify the area of work to be subjected to surveillance and shall provide necessary instructions. The timing, frequency, or schedule for the surveillance shall be coordinated with the work being evaluated to ensure maximum effectiveness with minimum impact on the progress of the work, b)
Ouality AsEltance Audits A comprehensive system of planned and periodic audits shall be implement'ed to verify compliance with all-aspects of the Quality Assurance Program and to determine the effectiveness of the program. The audits shall be performed in 4-7 Revision 10.
a
accordance with written procedures or checklists' by appropriately trained personnel not having direct responsibilities for the work being audited.
Depending on the nature of the function being audited, the audits are conducted in a performance-based manner to the maximum extent practical. The audits are supplemented by performance-based and compliance oriented surveillances, the results of which become part of the final audit package. The General-Offtee Quality Assurance Wii6siisshi Manager and GNS Quality Assurance ppeisti6ni Manager shall have the responsibility and authority for planning and executing j
Quality Assurance Audits identified by approved QAPs. However, the SRAB, or any manager or executive in the chain of organization abcvc the liQyd ihcludisp,[lli[j Site-Manager gjceJPie~sidsnl%NiicisE, or above the Quality Assurance Supervisors and Managers may initiate and carry out special Quality Assurance Audits within the guidelines provided by this Quality Assurance Program. Audit results shall be reported in writing to the NPG Management in accordance with the requirements of QM-5 NQPi and the results shall be reviewed with the Management responsible for the area of activity audited.
Appropriate follow-up action shall be taken and documented as directed by the appropriate Quality Assurance Manager or Supervisor.
Internal instructions and guidelines include descriptions and timing of types of audits to be performed; information for initiating and performing auditsd and information for preparing audit reports.
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Each QAP will be implemented through the use of the appropriate checklist. ; On the basis that some Quality Assurance Audits are to be conducted or directed by management, it is essential to maintain a high degree of flexibility in the manner of conducting an audit. It is intended that the QAPs provide audit guidelines to assure that areas to be audited are sufficiently defined in advance and that audit personnel are adequately prepared to make a meaningful audit with a minimum ;
of interference with the progress of the work. Also, flexibility.is required to permit the auditor to adapt his procedures to the conditions existing at the time the audit is made.
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5.0 METHOD'OF IMPLEMENTATION The CNS QA Program for Plant Operations will utilize the guidance provided by NRC '
publications WASH-1283 (5-24-74), WASH-1284 (10-26-73), and WASH-1309 (5-10-74) (" rainbow" series) except as noted in the " Specific Exceptions" of this section.
The existing operational QA Program does not address all of the detailed requirements set forth in the " rainbow books." A detailed review has been made to determine where the CNS QA Program differs from the ANSI Standards cited in the " rainbow books. "
i With respect to the applicability of the " rainbow books" and the associated standards,-
it is impracticable to apply all of the requirements set forth by these documents to a plant for which important, and (in some respects) irreversible commitments, were made at the start of commercial operation (1974). It is also impracticable to apply i
requirements to an operating plant which were intended solely for the design and construction phase. In the event that construction activities are undertaken, the District.
l will commit to compliance with the applicable portions of the WASH Series ANSI Standards. It is NPPD's intent to apply quality standards to maintenance, repair, and -
]
modification activities which will provide results which are equal to or better than the original construction.
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The detailed methods of implementation shall be as provided for in WiIfg?siid ipprygja65Edtiiss NQPs, QAS, and QAPs prepared in accordance with Section 4.0.
The Quali:y Assumnee jsyisiisibis Managers or designees shall review and comment on the NPG procedures to ascertain that necessary quality requirements are included.
Procedure changes will be incorporated as necessary to correct identified control deficiencies or needs. Differences of opinion on QA comments shall be resolved as indicated in Section 3.2.3.
After review of the various NPG procedures and manuals, the Quality Assurance Managers shall review the appropriate NQPs7 QAls; and QAPs for the purpose of assuring that the overall QA Program objectives continue to be accomplished in each segment of the work to which this QA Program applies.
i l
Quality Assurance activities shall be coordinated with the SRAB and SORC.
QA activities shall be conducted in a manner and on a schedule ta assure organization, supervision, communications, and technical and administrative practices _
clearly provide for smooth, orderly, controlled, and safe execution of all safety-related functions.
Written reports of all QA activities, including descriptions of deficiencie: and resolution thereof, shall be incorporated into the official QA file. Corrective action on deficiencies shall include resolution of the specific deficiency and verification that corrective action has been implemented to prevent occurrence of similar deficiencies 5-2 Revision 10
in the future. A report of QA-Audits performed (internal and external) shall be submitted to th'e Vice President - Prod =tica Ki@sj by the' Division Manager of
_ Quality Assurance annually.
The Quality Assurance Staff shall maintain an up-todte summary of the CNS Qitality II Assurance Policies, Procedures,. In;; ration;, and' Plans, showing how' this I
i QA Program for Operation implements the NRC guidelines contained in 10CFR50, I
h Appendix B.
i I
1 i
l I
H
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6.0 RECORDS RETENTION AND DISPOSITION Instructions have been prepared by the responsible organizations to provide guidelines for CNS and CGO record retention and disposition in accordance with this policy document and applicable regulatory criteria. As a minimum, these procedures cover-the following:
a)
Records content and location; b)
Principal location from which records are to be controlled; i
l c)
Complete records inventory and master index; 1
l l
1 d)
Conditions of storage, access, and security; i
e)
System of records identification, retrieval, and control; f)
System of records transfer and disposal.
'l Quality Assurance records (reference 7.9) will be entered into the controlled records '
system after4 hey 4mve-beemdedientedr-TMuledientionweurs-whemthe-netivity-to-the l
doeument-beecmes part-of-the-operating-condition-of-the-plant-pe[fNS[N424 l
@liiieissnts?
t 6-1 Revision 10
7.0 REFERENCES
The following documents were used in the preparation of the Quality Assurance
. Program for Operation of the Cooper Nuclear Station. It is intended that these documents be used on a continuing basis in the performance of Quality Assurance activities for station operation since they offer measurement criteria against which the QA Program can be evaluated.
7.1 Quality Assurance Criteria for Nuclear Power Plants 10CFR50, Appendix B t
(USNRC).
7.2 Standard of Administrative Controls for Nuclear Power Plants, American National Standard ANSI 18.7 - 1972.
7Property "ANSI code" (as page type) with input value "ANSI 18.7 - 1972.</br></br>7" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process..3 Updated Safety Analysis Report, Cooper Nuclear Station, Nebraska Public Power-District (NRC Docket 50-298).
7.4 Environmental Report--Operating License Stage, Cooper Nuclear Station, Nebraska
- Public Power District (NRC Docket 50-298).
7.5.
Cooper Nuclear Station Procedures Manual.
7.6 Safety Rules, Nebraska Public Power District.
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7.7 Safety Guides for Water-Cooled Nuclear Power Plants (USNRC), as appropriate.
7.8 Quality Assurance Requirements for Nuclear Power Plants ANSI N45.2 - 1977.
7Property "ANSI code" (as page type) with input value "ANSI N45.2 - 1977.</br></br>7" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process..9 Requirements for Collection, Storage, and Maintenance of Quality Assurance Records for Nuclear Power Plants ANSI N45.2.9 - 1974.
7.10 Quality Assurance Terms and Definitions ANSI N45.2.10 - 1973.
7.11 Quality Assurance Requirements for the Design of Nuclear Power Plants ANSI N45.2.I1 - 1974.
7.12 Requirements for Auditing of Quality Assurance Programs for Nuclear Power Plants ANSI N45.2.12 - 1977.
7.13 Supplementary Quality Assurance Requirements for Control of Procurement of Equipment, Materials, and Services for Nuclear Power Plants ANSI N45.2.13 - 1976.
7.14 CNS Radiological Technical Specifications.
7-2 Revision 10 I
FIGURE 1 Nebraska Public Power District NUCLEAR POWER GROUP QUALITY ASSURANCE DIVISION CA QA Staff
- Assessment Personnel Supervisor (4)
President and Vice-President Chief Executive Production Quality Office Assurance Assessment Manager
@M*
j l
QA Supplier
- Pemonnel Supervisor Vice President -
1 (4)
Clerk Nuclear Secretary j
Administrative j
Secretary II Dtvision Manager Quality QA
- CA Sta'f
- Assurance Programa Personnel Supervisor (4)
Qua!W Assurance Operations Manager QA Staff
- CA Audit
- Personnel Responalbie for QA Second Level Secretary Supervisor Surveillances and Third Level CA Audits.
Responsible for Fourth Level Assessments i
...._.............- Direct Communications Steno-Secretary i
81 Rev.10
)
1
TABLE 1 SYSTEMS AND MAJOR COMPONENTS
- COVERED BY THE OUALITY ASSURANCE PROGRAM I.
NUCLEAR STEAM SUPPLY SYSTEM A.
Reactor Primary Vessel B.
Reactor Primary Vessel Supports C.
Control Rods and Drive System Equipment Necessary for Scram Operation D.
Control Rod Drive Housing E.
Fuel Assemblies F.
Core Shroud G.
Steam Dryer II.
Steam Separator II.
ADS - Automatic Depressurization System B.
HPCI - High Pressure Coolant Injection System C.
LPCI - Low Pressure Coolant Injection System D.
CS - Core Spray System E.
RCIC - Reactor Core Isolation Cooling III.
REACTOR PROTECTION AND ENGINEERED SAFEGUARD SYSTEMS A.
Rod Sequence-Gontrol-System ICC, Standby Liquid Control C(D: Standby Gas Treatment D;E Diesel Generators 9-1 Revision 10
y Table 1 (Cont'd.)
ElF: Electrical Aux Power r
1.
Critical 4160 V Equipment i
2.
Critical 480 V Equipment
$Gr Neutron Monitoring Systems 3
- APRM f_M_ erais_P6_ssEEEgsM. 5_hil5.if 1.
m 2.
I'RM [QuesiF&ly[Rshi^6]Musita{
3.
LPRM ((E5%goMRiiiRM5di;i5i 4.
RBM [Q5d}l5E[M@f6f 5.
SRM E @ RRidgyMMt5j 6.
Tll- @jTiiv~Ejiiih{JA[C5KPibbs GlHr DC Power Supply i
Hjh Nuclear System Leak Detection ljh Containment Isolation System JjK:
Nuclear Boiler and Related Instrumentation Kjbr Primary Containment 1
- lyM Rod Position Indicator IV.
NUCLEAR FUEL SYSTEMS A.
Refueling Interlocks for Fuel Handling and Vessel Servicing Equipment B.
Fuel Pool Liner and Gates C.
Fuel Pool Cooling and Cleanup.
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'1
Table 1 (Cont'd.)
1 1
V.
RADIOACTIVE WASTE DISPOSAL SYSTEMS A.
Process Radiation Monitoring System 1
1.
Off-Gas ltidisiid((itflMdriig Ven "ip; ";diraion Monitoring 1
2.
Off C= Menitoring q
'l 3.
Aug Off Os Meni:cring
-l 2{4r Main Steam Line Monitoring
,j q
3]&:
Reactor Building Vent Monitoring (GE) l K6:
Drywell and Suppression.Sys'em Leak Rate t
Liquid Process Radiation Monitoring BATjRidi@lijpM@}f@SidQ#@nj u
o 1
I_fCsd@Wastmg;jystent 2?Q]Rsdi,6AMipysif$hiMiihj VI.
OTHER SUPPORT SYSTEMS q
A.
Reactor Equipment Cooling
- )
B.
_ Emergency Bypass Function on Control Room Heating, Vent, and AC.
D.
Reactor Recirculating (Pressure Retaining Parts Only)
E.
Class I,11, and lil Code Items -
1 F.
-Reactor Feed Pumps (Pressure Retaining Parts Only)
G.
Reactor Building H&V H.
Fire Protection I.
Security
- J.
Instrument Air 9 Revision.10 -
~_
Table' 1 (Cont'd.)
~ VII.
STRUCTURES (SEISMICS)
A.
Reactor Building B.
Control Building C.
Elevated Release Point D.
Intake Structure E.
Diesel Generator Building F.
Radwaste Building (Below Grade)
- Note -
1.
This listing is not intended to be all inclusive.
2.
Application of the QA Program to these systems and components shall be consistent with the safety-related significance of the system or component.
1 0
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.-~.
Table 2 FOURTHREE LEVEL QUALITY ASSURANCE PROGRAM EXPLANATION OF FII5ST, SECOND, AND THIRD 2AND FOURTH LEVEL QA RESPONSIBILITIES a)
FIRST LEVEL-Work Performance c)
THIRD LEVEL-Ouality Assurance and Ouality Control.
Audit /Sasullliii6i.
Each person performing work for QA Staff is responsible for CNS is charged with the first-line maintaining surveillance and audits responsibility for adherence to of the work at CNS and the CGO to quality practices and procedures. An assure that Quality Control and individual other than the one doing inspection programs are being the work (not to include immediate implemented and that quality supervisor) will have primary requirements are in fact being met.
responsibility for Quality Control.
This includes verification that Personnel at this level are charged activities are properly performed and with the responsibility for direct procedures are adequate for the inspection, witnessing, and sign-off, activity they prescribe.
Persons attesting that work has been performing these audits are not performed in accordance with the directly involved in the day-to-day quality requirements of the Inspection or Quality Control controlling documents, functions.
Audits and/or surveillances will normally _ be b)
SECOND LEVEL-SurveiHanee!
performed by or under the direction Mg EMEsaisi/Siip6FVis6ir of the appropriate QA Manager. In OyesieW.
addition, SRAB shall be responsible for reviewing the results of audits Supervision and management and follow-up audits as described in personnel are responsible for Technical Specifications.
The providing workers and QC people Quality Assurance Staff is also with the proper procedures and responsible for the evaluation of guidance for performing quality audit results and for verifying that work.
These Managers and identified corrective action Supervisors are then responsible for requirements haye been second level servedleneeleudit implemented.
byEMissy as appropriate for work invoEd Jity df^ fFDUkTHMEEV1MUViliTV
..~
^
" Assessment Assur=ce M=ager
=d COO Quality-Assurance M=ager Ttis CN(lijsyshigjfpaidTsppNiioji PWisp g jisf @ TrH W ijhyj are responsible for assuring that Essessments are'not'diket}y irivolved Mth8T @ %ju$lii @ ond j
controlling documents for I
Qnality[ Control nEtions!
safety-related _ activities include appropriate quality requirements.
9-5 Revision 10
Table ~ 2
~
FOUR LEVEC QUALITY' ASSURANCE PROGRAM EXPLANATION.;OF FIRST,- SECOND, AND THIRD /AND TOURTli LEVEI{Qk RESPO.NSIBILITIES
,, n.
,n, d)l TF'OURT10 ILEV BCTOsalit v
~
Assessment (con't)
Assessnientsl:;.l:.wi_Ilfj n6rnislip!:1 ;.;be performsd under tiiefdireetion of the Q'ualitp-l :"Assuraiice.1 jAssessment Manages or Senior.line' Management
~
personnel; or at the' discretion of on a site or off-site safety review l bodies)
L Suchf assessmenfs 'are co6 ducted l to provide the highest lef'el of overview of l implementation :Lof T thii;:; Quality Assurance Program. iasi ;herein described;
)
9-6 Revision 10
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